Indiana University Waste Management Program October 30, 2017 1. INTRODUCTION 1.1. Purpose and Background Indiana University Environmental Health and Safety (IUEHS) has developed this Program to establish standard procedures for safe, environmentally sound and compliant management of wastes generated on any IU campus in accordance with all local, state and federal regulations. These regulations include but are not limited to the Environmental Protection Agency’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations 40 CFR 239-282, and the Toxic Substances Control Act (TSCA) polychlorinated biphenyls (PCB) regulation 40 CFR 761. 1.2. Scope This Program applies to all faculty and staff of Indiana University that participate in any activity that results in a general refuse product of any kind, including but not limited to laboratory research, maintenance, grounds keeping, and academic instruction. The objectives of this Program are to protect human health and the environment in compliance with all government regulations by preventing the release of contaminants through sound, best management practices for waste generation, handling and disposal. 2. AUTHORITY AND RESPONSIBILITY 2.1. Indiana University Environmental Health and Safety (IUEHS) is responsible for: Developing and implementing the Waste Management Program; Providing training and/or technical guidance on waste management requirements and procedures to all affected employees; Ensuring regulatory compliance and acting as the University liaison for regulatory agencies that oversee waste related activities and/or conduct on-site inspections; Maintaining waste contracts with vendors for the respective campuses; and Facilitating chemical wastes shipments. 2.2. Departments are responsible for: Enforcing Waste Management Program provisions among employees; Ensuring that all employees who handle waste receive initial waste management training from IUEHS and task-specific training in waste management procedures as well as annual refresher training if required by this Program; Facilitating waste minimization efforts consistent with the IU Waste Minimization and Pollution Prevention program; Providing all necessary resources to manage all waste generated within the department in a safe and compliant manner; Reporting waste management non-compliance to IUEHS for the respective campus immediately upon discovery; Ensuring that all staff utilize the services of IUEHS for chemical waste pick-up and disposal for the respective campus; and Funding regulatory fines levied by state or federal agencies that result from mismanagement of waste by individual(s) within a department.
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Indiana University Waste Management Program October 30, 2017
1. INTRODUCTION
1.1. Purpose and Background Indiana University Environmental Health and Safety (IUEHS) has developed this Program to establish standard procedures for safe, environmentally sound and compliant management of wastes generated on any IU campus in accordance with all local, state and federal regulations. These regulations include but are not limited to the Environmental Protection Agency’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations 40 CFR 239-282, and the Toxic Substances Control Act (TSCA) polychlorinated biphenyls (PCB) regulation 40 CFR 761.
1.2. Scope This Program applies to all faculty and staff of Indiana University that participate in any activity that results in a general refuse product of any kind, including but not limited to laboratory research, maintenance, grounds keeping, and academic instruction. The objectives of this Program are to protect human health and the environment in compliance with all government regulations by preventing the release of contaminants through sound, best management practices for waste generation, handling and disposal.
2. AUTHORITY AND RESPONSIBILITY
2.1. Indiana University Environmental Health and Safety (IUEHS) is responsible for:
Developing and implementing the Waste Management Program;
Providing training and/or technical guidance on waste management requirements and procedures to all affected employees;
Ensuring regulatory compliance and acting as the University liaison for regulatory agencies that oversee waste related activities and/or conduct on-site inspections;
Maintaining waste contracts with vendors for the respective campuses; and
Facilitating chemical wastes shipments.
2.2. Departments are responsible for:
Enforcing Waste Management Program provisions among employees;
Ensuring that all employees who handle waste receive initial waste management training from IUEHS and task-specific training in waste management procedures as well as annual refresher training if required by this Program;
Facilitating waste minimization efforts consistent with the IU Waste Minimization and Pollution Prevention program;
Providing all necessary resources to manage all waste generated within the department in a safe and compliant manner;
Reporting waste management non-compliance to IUEHS for the respective campus immediately upon discovery;
Ensuring that all staff utilize the services of IUEHS for chemical waste pick-up and disposal for the respective campus; and
Funding regulatory fines levied by state or federal agencies that result from mismanagement of waste by individual(s) within a department.
2.3. Principal Investigators and/or Supervisors are responsible for:
Ensuring employees have access to safety data sheets, and know the hazards of all chemicals used in their area;
Ensuring that all employees who handle waste receive initial waste management training from IUEHS and task-specific training in waste management procedures as well as annual refresher training if required by this Program;
Ensuring employees and students are properly instructed in the requirements of this program
Ensuring standard operating procedures based on this Program are developed for waste management, waste minimization, and handling emergencies;
Ensuring employees and students are supervised as needed when performing standard operating procedures;
Enforcing Program requirements within their areas of responsibility; and
Contacting IUEHS for the respective campus if a regulatory inspector arrives.
2.4. Employees are responsible for:
Learning and following Waste Management Program requirements for comprehensive waste management;
Assuming personal responsibility for compliant identification, labeling, storage, and disposal of all wastes generated as a result of his or her job duties; and
Developing and implementing waste reduction methods whenever feasible.
3. Program Elements
3.1. General Requirements Waste materials are typically divided into four broad categories: biological, chemical, general refuse, and radiological. Each of these waste types has unique handling and disposal protocols based on regulations and best management practices. General refuse is not covered by this Program except for certain non-regulated chemicals that require special handling in order to avoid impermissible or unsafe disposal. Radiological and biological wastes are covered in the Radiation Safety Manual and IU Biosafety Manual respectively, and are therefore not detailed in this Program. Untreated biological waste, regulated hazardous waste, and radioactive waste must not be placed in general refuse dumpsters. With limited exceptions, restrictions are also in place for drain disposal of certain waste types and disposal of debris that is contaminated with any of these waste types. Campus dumpsters and compactors must remain free of liquid or semi-liquid waste of any kind. The primary focus of this Program is on chemical waste handling and disposal. This waste category is divided into five types based on regulatory requirements:
Hazardous waste as defined in 40 CFR 261, incorporated by reference in 329 IAC 3.1-6;
Universal waste as defined in 40 CFR 273, incorporated by reference in 329 IAC 3.1-16;
Polychlorinated biphenyl (PCB) waste as defined in 40 CFR 761, incorporated by reference in 329 IAC 4-6;
Electronic-waste as defined in 329 IAC 16; and
Non-regulated waste with special handling requirements; this class includes materials for sewer disposal as well as materials that are not regulated, but present safety or logistical concerns due to their physical characteristics.
Detailed guidance for waste management is published in the Indiana University Waste Management
Guide found in Appendix B of this Program.
3.2. Additional Guidance Certain additional materials require special handling due to complex regulatory oversight. These can include:
Controlled Substances: The U.S. Drug Enforcement Agency (DEA) regulates Schedule I-V controlled substances according to 21 CFR 1300-1321. Compliant recordkeeping and disposal of these materials is the responsibility of the authorized registrant. Registrants must be aware that certain controlled substances are also regulated as hazardous waste under RCRA. IUEHS can provide additional guidance, and has limited ability to provide disposal for controlled substances in accordance with DEA requirements. See the IU Controlled Substances Program for Researchers (Non-Practitioners).
Mixed Waste Categories: Wastes that contain any combination of hazardous, biological or radiological waste can pose disposal challenges for IUEHS. The protocols for disposal of such mixtures vary by campus, and are outlined in the campus-specific waste management procedures found in the Indiana University Waste Management Guide (Appendix B).
4. TRAINING AND RECORDKEEPING IUEHS personnel, trained in hazardous waste management, will provide classroom or online instruction to incoming employees that will be performing waste handling functions to ensure that employees understand their roles and responsibilities in order to comply with applicable waste management regulations. All employees who transfer waste from the point of generation to a separate accumulation area or to an IUEHS storage location, must complete the applicable online Waste Management and Spill Response training annually. It is the responsibility of supervisors, and/or principal investigators in the case of laboratories, to ensure that employees who will handle waste are identified, and that proper on-the-job training and annual training is completed as required in this Program. On-the-job training must include standard operating procedures for waste handling and emergencies.
5. REFERENCES
DEA Controlled Substance Regulations 21 CFR 1300-1321
Electronic Waste Regulations 329 IAC 16
Indiana University Mercury Reduction-Elimination Program
Toxic Substances Control Act (TSCA) PCB regulation 40 CFR 761
Indiana Department of Environmental Management (IDEM) policy for the management of solvent-contaminated wipes (based on 40 CFR 260.10, 40 CFR 261.4(a)(26), and 40 CFR 261.4(b)(18)).
Indiana University Waste Minimization and Pollution Prevention Program
Indiana University Environmental Health and Safety (IUEHS) developed this Guide based on local, state
and federal regulations applicable to a broad variety of waste generated at the University. In addition,
this Guide supplements Program requirements for the IUEHS Waste Management Program. Read and
follow this Guide carefully. Indiana University employees play a vital role in the proper management of
waste through their daily activities.
1.1 Purpose and Use of This Guide
This Guide serves as a resource for IU employees who participate in activities that generate
waste from various campus operations. The primary focus is on chemical waste. Several key
concepts are covered, including: an overview of waste regulations; waste minimization and
recycling; IU waste collection programs; disposal of specific waste streams; and handling
chemical spills. Hyperlinks throughout the text provide direct navigation to additional
information as needed. This Guide does not address detailed procedures for managing
radioactive or biological wastes. For more information, refer to the Radiation Safety Program or
the IU Biosafety Manual as appropriate.
Each IU campus has unique infrastructure that requires certain procedures remain campus-
specific. Therefore, some protocols are provided in campus-specific sections of this document.
1.2 Key Terms and Definitions
Accumulation – Continuous addition of waste into container(s); also refers to the time-period over which waste is collected and stored (e.g. “accumulation start date” on a waste label).
Accumulation Container – A container used to collect waste in a satellite accumulation area.
Biohazard – Biological material that contains, or may contain pathogens that can cause disease in humans or animals, or that poses any other risk requiring inactivation or disinfection before final disposal.
Controlled Substance – A drug or chemical whose manufacture, possession or use is regulated by the United States Drug Enforcement Agency (DEA).
Consolidate/Consolidation – Mixing similar wastes together, generally from smaller containers into larger accumulation containers.
Cylinder – A container used to store pressurized liquid or gas.
General Refuse – Items that can be discarded in campus trashcans, dumpsters or compactors because they do not pose hazards that require treatment, special handling or disposal.
Generator – A person or entity that creates hazardous waste.
Hazardous Waste – Materials defined as hazardous by the Environmental Protection Agency (EPA) due to hazards they pose to human health or the environment; includes listed and characteristic wastes (see Section 2).
Personal Protective Equipment (PPE) – Garment or equipment that employees wear to protect themselves against chemical exposure hazards. Examples include safety glasses, gloves, and lab coats.
Satellite Accumulation Area (SAA) – Any area where hazardous waste is generated and stored until containers are full, up to 55 gallons total for all waste (See Section 2). SAAs must be at or near the point of waste generation, within the same room.
Universal Waste – Classification of hazardous waste managed under a special exemption to encourage recycling of certain materials. These wastes are still subject to certain regulatory requirements. Materials that can be managed as Universal Waste are:
Batteries
Fluorescent light bulbs/lamps
Mercury containing devices
Pesticides
Unknowns – Unidentified chemical waste resulting from lack of proper identification or labeling.
Waste Chemical – Any expired, spent or unwanted chemical, chemical mixture, or chemical product, including hazardous and non-hazardous wastes.
Waste Stream – Generic term for either specific waste generated by a continuous process, or for wastes that are similar, but come from various campus generators. Examples include non-chlorinated solvents, HPLC waste, used oil, etc.
1.3 The Role of Environmental Health and Safety
The principal role of IUEHS is to serve as the primary University resource for all matters
pertaining to occupational health, safety, and environmental management. IUEHS provides
technical guidance, compliance assistance, quality assurance, remediation oversight, and
training to the campus community.
For the purposes of waste management, the main role of IUEHS is to provide waste
management oversight and services in conjunction with technical assistance, training, and
support resources so that all IU employees are aware of their individual responsibilities in
helping the University meet the following goals:
Ensure all waste materials are managed in a way that protects the health and safety of faculty, staff, students and visitors to the University;
Use the most responsible and environmentally sound management and disposal methods as are practical, and that prevent release into the environment;
Reduce the quantity and/or toxicity of chemical waste generated by the University to the lowest level possible;
Comply with all local, state and federal government regulations regarding waste management and disposal; and
Make accurate determinations of regulatory status and sound disposal decisions for all
waste generated at IU.
IUEHS will update this Guide as necessary to reflect any applicable changes in procedure or
The success of the Waste Management Program depends on the conscientious efforts of all IU
employees. When waste materials are mismanaged, they have the potential to threaten human
health and pollute the environment. To ensure safety and compliance with the law, the first
responsibility of all employees is to follow the procedures in this Guide. Additional individual
responsibilities are to:
Understand the hazards of all chemicals in your work area. Safety Data Sheets (SDS) must be available for all chemicals that you work with.
Identify and label all chemical containers accurately and promptly so that unidentified wastes (“unknowns”) are not generated.
Label, store and package wastes according to the procedures in this Guide until IUEHS for your respective campus can take possession of them and/or arrange for off-campus disposal.
Contact IUEHS for your respective campus for assistance with questions on how to handle or dispose of a waste material.
Include the waste minimization strategies outlined in Section 3 of this Guide in written procedures when possible, and make every effort to reduce the amount of waste you generate.
Section 2: Regulatory Overview
All waste must be evaluated to determine whether or not it is regulated as a “hazardous waste” under
the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA). Through
RCRA regulations, EPA requires that all hazardous waste be properly identified, labeled, stored, treated
and disposed. From a regulatory standpoint, EPA and the Indiana Department of Environmental
Management (IDEM) defines a hazardous waste as:
A listed hazardous waste (specifically identified by an alpha-numeric code from one of four lists maintained by EPA), or
Waste that exhibits certain hazardous characteristics (also identified with an alpha-numeric code) as determined by standardized testing procedures.
IUEHS always makes the determination as to whether or not a waste is regulated by RCRA. Usually the
determination is based on information provided on the waste container, the Chemical Waste Label, and
SDS. Occasionally, a waste sample must be analyzed to obtain more detailed information before a
determination can be made. Annex 1 details the RCRA regulatory requirements under which IUEHS
makes hazardous waste determinations.
For practical purposes, IU employees should manage all chemical waste as hazardous unless otherwise
specified in this Guide or IUEHS has specifically made an evaluation and determined that a waste can be
managed in another way. It is important to note that some wastes are restricted from sewer or landfill
disposal even if they are not regulated by RCRA as hazardous waste. Specific disposal guidance for the
most common waste streams generated at IU can be found throughout this Guide.
It is also important to understand the following key concepts:
Satellite Accumulation Areas (SAAs) are what EPA calls individual locations, including laboratories, where hazardous waste is generated. The requirements for management of waste in SAAs can be found in Attachment B.
Indiana University facilities are subject to routine, unannounced regulatory inspections. IDEM typically conducts these inspections; however the EPA also has this authority. Inspectors visit SAAs as part of the inspection process. Always be courteous and cooperative with regulatory inspectors if they visit your area.
Section 3: Waste Minimization
As required by the EPA, IU has established procedures to minimize the volume and/or toxicity of
hazardous waste produced at the University, and to manage any waste that must be produced in the
most responsible way possible. Some waste minimization methods are outlined in this section, and
more information can be found in the IU Waste Minimization and Pollution Prevention Program.
3.1 Substitution
Often a non-hazardous or less toxic chemical can be used in place of a more hazardous chemical
in a given process. Some specific examples can include:
Citrus-based solvents instead of chlorinated solvents,
Low VOC latex and water based paint instead of oil based paint,
Eco-friendly alternatives for stripping instead of methylene chloride based strippers,
Detergent or surfactant based cleaners instead of corrosive cleaners,
Pump sprays instead of aerosol cans,
Low-mercury “green” fluorescent bulbs or LED bulbs instead of high mercury fluorescent bulbs, and
Baits, diatomaceous earth, borates or botanicals (like Pyrethins) instead of chlorinated pesticides or carbamates.
3.2 Volume Reduction
Whenever possible, do not mix hazardous chemical waste destined for IUEHS disposal with
wastes that can be disposed through recycling, sewer or trash disposal. This increases the
volume of regulated waste for off-site disposal. Another option is using micro-scale chemistry,
which greatly reduces the volume of waste produced.
3.3 Inventory Management
Carefully maintain an inventory and ordering system that reduces unnecessary or surplus
containers. Check your current stock before ordering new chemicals. It may also be possible to
borrow chemicals from other departments, which can reduce costs.
Also consider that many chemicals have a limited shelf life. Please check inventory before
ordering large quantities of stock chemicals, and do not buy materials in bulk unless there is a
true need for large volumes of a reagent. The amount saved by purchasing bulk quantities may
be offset by excess, unneeded material that often ends up as waste.
3.4 Recycling Many types of waste can be recovered for recycling. This includes things like mercury, glycols,
batteries, and oil. The specific materials that can be handled for recycling by IUEHS are different
for each campus. Other departments collect general recycling and surplus property.
Arrangements may also be made with an approved vendor for recycling materials such as scrap
metal and fluorescent lamps. General recycling and surplus property are managed by Facilities
Services/Physical Plant. Keep in mind, empty chemical containers cannot be recycled.
This section contains procedures specific to laboratory waste handled by laboratory personnel familiar
with chemical operations. IUEHS collects a wide range of chemical waste from laboratories, but
alternative disposal options are acceptable for some of these wastes. Refer to Attachment A of this
Guide for a list of disposal options for common laboratory chemicals. Contact IUEHS for your respective
campus for questions regarding any chemical not found in Attachment A. There are three basic routes of
disposal of laboratory chemical waste:
Sanitary sewer or trash disposal of non-hazardous materials;
Acid-base neutralization, followed by sewer disposal. Note: Any other type of treatment must be part of an experimental procedure to be considered legal; and
IUEHS management for offsite treatment or recycling - Campus-specific waste management procedures are found in Sections 5-7. Those sections outline how to correctly identify, package, and segregate waste; waste storage requirements; and IUEHS waste collection for both laboratory and non-laboratory operations.
4.1 Acid-Base Neutralization
Wastes designated in Attachment A: Disposal Options for Specific Chemicals for acid-base
neutralization may be handled in-lab using the procedures below. Please note the following
restrictions:
Strong, concentrated acids or bases are limited to quantities of 25 milliliters (ml) or less, and must be diluted 10 to 1 before being neutralized and discharged to the sewer. Quantities that exceed 25 ml must be managed by IUEHS.
Oxidizing acids including chromic, perchloric and nitric acids in any amount are to be managed by IUEHS.
Acids or bases that contain heavy metals must be managed by IUEHS.
Neutralization Procedures
Caution: vapors and heat are generated during neutralization. Note that acid-base
neutralization is not required for disposal with IUEHS. When in doubt, or if neutralization is
not feasible, any material can be placed in disposable containers for IUEHS management.
Perform all steps slowly and keep containers cool while neutralizing.
Acid neutralization: Make a basic solution using a large volume of cold water and an appropriate inorganic base. Stir the solution while slowly adding diluted acid.
Base neutralization: First add the base to a large vessel containing water. Slowly add an appropriate inorganic acid.
Allow the contents to react for 15 minutes to dissipate any heat before testing the pH. The container should not be hot, and the contents should not be smoking. If the container is still hot after 15 minutes, allow the reaction to continue until the heat has dissipated before continuing to the next step.
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Test the neutralized solution to confirm a pH between 5 and 9, and flush to the sewer with at least 20 parts water.
4.2 Sewer Disposal Limited volumes of chemical waste can be disposed by sanitary sewer under certain conditions.
If a material meets the following criteria*, it may be flushed to the sewer with at least an equal
volume of water.
The material must have a Hazardous Materials Identification System (HMIS) or National Fire Protection Association (NFPA) rating of 0 or 1 for health and fire, and a rating of 0 for reactivity. These ratings can be found on the material’s Safety Data Sheet (SDS) and/or;
A GHS rating of 4 or 5 for health and fire, and 5 for reactivity. Note: As shown in the figure below, the Global Harmonized System (GHS) rating system is the opposite of HMIS and NFPA, with Category 1 materials exhibiting the highest level of hazard and category 5 exhibiting the lowest level of hazard;
and;
Volume of material is limited to 5 gallons of chemical per discharge for liquids and 1 kilogram for solids and;
Must be liquid or a water soluble solid and;
Must not be a severe irritant or lachrymator and;
Must not emit strong or noxious odors (examples include mercaptans (thiols) or amines) and;
Must not be harmful to aquatic life or dangerous to the environment as specified on the label or SDS.
*Note: Dilute solutions of some materials with a higher HMIS/NFPA rating before dilution are acceptable for sewer disposal.
Many common sewer-acceptable chemicals are listed in Attachment A of this Guide, including some solutions. Contact IUEHS for your respective campus with any questions.
IU Bloomington Waste Management 15
Section 5: IU Bloomington Waste Management
The success of the IU Waste Management Program depends on the cooperation and conscientious
efforts of everyone on the IU Bloomington (IUB) campus. IUB EHS collects a wide variety of chemical
waste from laboratories, shops, offices, etc. for off-site treatment or disposal. This section outlines the
general procedures for managing waste from laboratory and non-laboratory operations on the IUB
campus. Waste handling and disposal protocols for specific waste types commonly generated by both
of these operations is also included. The procedures and methods provided must be followed to ensure
your health and safety, as well as regulatory compliance. If you have any questions, contact IUB EHS
immediately.
5.1 IUB Laboratory Waste Management The following general requirements apply to waste generated by laboratory operations.
Laboratories generate a large variety of waste types. Those waste types should be managed as
hazardous waste, unless otherwise specified by this Guide or IUB EHS staff.
General Requirements
1. Identify and label - All waste must be identified and labeled!
When a chemical waste is first created, its identity must be recorded. Waste accumulation
containers are to be labeled at the time the first waste is added. If more waste is
subsequently added to a waste container, constituents must be added to the container label
as needed. Tags should not be dated until the container is ready to transfer to IUEHS. IUB
provides a printable waste tag template (Figure 5A) that must be used to identify waste
materials and to fulfill IU’s waste minimization obligations. IUB EHS will not accept waste
that is not labeled properly. If the waste cannot be identified, the requirements in Section
5.3 for unknowns will apply.
IUB EHS Waste Chemical Tag information:
A printable template for IUB EHS Waste Chemical Tags (“tags”) is available online at http://ehs.iu.edu/docs/printable%20waste%20tags.pdf.
Tags must state each chemical constituent in the waste container and corresponding percentages. Waste constituents must be spelled out completely. Avoid acronyms, chemical structures or abbreviations. Provide percentages of all chemicals in a mixture, including water. The percentages must add up to 100%. Please write legibly.
Affix tags to containers with a rubber band, twist tie, or tape. Or, an electronic version of the tag can be printed on adhesive stock and affixed directly to disposable containers, Ziploc® bags, or boxes of containers for disposal. An adhesive tag can be affixed to an index card for reusable containers - punch a hole in the corner and attach with a rubber band or twist tie, or place in a sleeve on the side of the container.
A “Hazardous Waste Label” (Figure 5B) with general contents, and running log of specific container contents, may be used as an alternative to a tag while waste is accumulating in reusable containers, until it is presented to IUB EHS when a completed tag is required. Alternatively, each time a reusable container is emptied by IUB EHS, a new tag can be started, kept in a sleeve on the side of the container, and updated until it is presented to IUEHS to be emptied and the completed tag is provided to IUEHS. Neither the Hazardous Waste Label nor the waste tag should be dated until the container is ready to transfer to IUEHS.
Waste chemicals in their original containers with legible, intact labels do not need to be re-labeled with a tag. However, the materials require a completed Hazardous Waste with Date label (date label) (Figure 5C) to be affixed on the container in a manner that does not obscure the chemical name. Small containers of the same material can be placed inside a closed Ziploc® bag or box, with a completed waste tag or date label. Note: If the bag or box does not close completely or the materials are different, each container will need a separate tag or date label.
More than one tag per container may be used if extra space is needed. Be sure to fill in information on the top two lines of the continuation tag; sign and date all tags when the waste is ready to transfer to IUEHS.
Do not date your tag until it is ready for disposal through a waste collection or IUB EHS pick-up. If you have close to 55 gallons of waste in your lab, and a waste collection or IUB EHS pick up is not scheduled within 72 hours, contact EHS immediately. Never exceed 55 gallons of waste in any one satellite accumulation area.
Note: If your lab generates this quantity of waste on a regular basis, contact IUB EHS for further guidance.
2. Ensure waste containers are appropriate and in sound condition – Wastes collected by
IUB EHS may be transported within buildings, on University streets, and eventually off of
University property after storage for up to 90 days. Therefore, chemical waste must be
packaged in containers suitable for extended storage and transportation.
Acceptable waste containers for common chemicals are as follows:
Flammable and halogenated solvents: Four-liter glass solvent bottles, four or eight-liter Nalgene bottles, one or five-gallon size metal cans, any safety can, or any original solvent container;
Strong acids and bases: Glass or compatible plastic bottles up to 4 liters in volume, original bottles preferred;
Miscellaneous organic and inorganic reagents: Original containers or their equivalent.
Do not use biohazard bags for storage of chemical waste.
All containers must have tight sealing caps or lids (no Parafilm® or tape in place of lids). If
your waste is in a container that does not close or does not have a lid, you will need to
transfer it to an acceptable container before presenting it to EHS. If you have any questions,
contact EHS prior to presenting the waste for disposal.
Notes: IUB EHS provides 5-gallon buckets with lids and 1-gallon wide mouth plastic jars that can be used for collection of compatible wastes. If you are going to reuse a chemical container for waste, it is your responsibility to insure that it is completely free of residue from its original contents before adding any incompatible waste to the container, and also that any labeling from the original contents has been removed or completely obscured.
3. Consolidate wastes wisely –When waste consolidation is not performed properly, it can
lead to increased safety risks and expense. However, using proper procedures for
consolidating wastes can be an efficient way to save space and resources. The procedures
below must be followed when consolidating waste:
Compatible waste from the same or similar processes can be consolidated into one waste container. Never mix incompatible materials together in the same container. Attachment C provides more information on compatibility.
Whenever possible, wastes that are different in form or chemical make-up (solids vs. liquid, solvents vs. aqueous) should be accumulated in separate waste containers.
o Never consolidate wastes consisting of oxidizers, strong acids (such as nitric and perchloric), or water-reactive material with other wastes. These materials should be disposed as individual wastes in the form they are generated.
Do not mix high hazard waste materials with low hazard waste materials, unless the experimental procedure requires it. Doing so may inadvertently create a large quantity of regulated hazardous waste where a much lower quantity may have existed otherwise.
If consolidation is unnecessary, you are unsure whether or not your waste is compatible with the waste in an accumulation container, or your waste accumulation container is poorly labeled – do not consolidate. Note: Never assume the contents of unknown or poorly labeled containers, and never consolidate unknown or unidentified wastes with other waste materials.
See Section 5.3 for specific information on consolidating laboratory solvents, acids and bases, and silica gel, as well as management of empty containers and chemically contaminated items.
4. Manage containers in accumulation areas properly - Proper management of containers
is imperative to ensure safety and compliance. Follow all requirements outlined in
Attachment B in addition to the following:
Ensure waste containers remain in sound condition as outlined in Section 5.1.
Keep ignitable waste away from ignition sources.
Keep the outside of containers free of contamination.
Do not over-fill containers. Note: Full means 90% or less to allow for expansion within the container.
Do not use biohazard bags for the storage of chemical wastes.
Safety cans are mandatory for ignitable solvents and advised for halogenated solvents. Safety cans must be in good working order (i.e. not rusted and able to spring closed and stay tightly sealed) or must be replaced. IUB EHS will request that cans be replaced when non-functioning cans are noted during a waste collection, and will confiscate cans if generators do not comply. IUB EHS does not supply safety cans. Glass bottles are discouraged, but will be accepted from labs that do not generate enough ignitable waste to justify maintenance of a safety can.
See Section 5.3 for specific information on the management of peroxide-forming agents, explosive or shock-sensitive materials, air reactive materials, and sharps.
5. Dispose – Once a waste accumulation container is full, or a chemical has been determined
to be a waste, it should be transferred to IUB EHS for disposal as soon as reasonably
possible.
Laboratories at IUB may deliver chemicals to IUB EHS staff in Chemistry A027 during predetermined hours for waste collections, or request a pick-up depending upon location. See the online Waste Collection Schedule to determine the procedure for your location.
Dispose of waste in a timely manner to ensure safety and compliance. Reminder: If you have close to 55 gallons of waste in your lab, it must be transferred to IUB EHS through waste collection or pick-up within 3 days. Contact IUB EHS immediately if these options are not available within that timeframe.
EHS will not accept waste that is not properly packaged, labeled, and dated. Any container or label corrections must be made before IUB EHS can accept waste. Call IUB EHS for assistance before waste is presented for disposal.
Figure 5A:
IUB EHS Waste Chemical Tag
Figure 5B:
IUB EHS Hazardous Waste Label
Figure 5C:
IU Bloomington Waste Management 19
Hazardous Waste Date Label
5.2 IUB Non-Laboratory Waste Management
Non-laboratory operations, such as facilities maintenance, information technology support, and
academic or administrative offices, are distinctly different from laboratories in the types and
quantities of waste that they generate as well as the physical facilities and locations on campus.
This section outlines the general requirements for managing non-lab waste materials. Additional
guidance on handling and disposal of specific waste types is found in Section 5.3.
General Requirements
1. Identify your waste. Below is a list of waste types common to non-research operations on
campus. Information about each waste type can be found in Section 5.3. This information
will guide you in identifying your waste and, for some wastes, in proper management of the
waste. Unless the waste specific information indicates otherwise, this section must be
followed for all wastes.
Aerosols
Antifreeze/glycols (under “non-hazardous waste”)
Asbestos containing materials
Ballasts (PCB and Non-PCB)
Cleaners (under “chemical waste”)
Compressed gases (propane, acetylene, etc.)
Electronic waste (E-waste)
Fuels and fuel/oil mixtures (under “chemical waste”)
so that your total quantity of chemical waste (unless designated as non-hazardous by this
Guide or EHS) remains under 55 gallons at all times.
Note: If you are approaching 55 gallons of waste, that has not been designated as non-hazardous, in your accumulation area, and a waste pickup is not scheduled within 72 hours, notify EHS immediately.
Some wastes, such as used oil, PCB ballasts, and Universal Waste have special labeling
requirements, and different accumulation time limits. See Section 5.3 under these specific
waste types for guidance. Chemical waste should be managed as hazardous waste unless
otherwise stated in this Guide.
3. Consolidate wastes wisely – Consolidating waste into fewer containers can be efficient
and can save space and resources if done properly. However, it can lead to increased costs
and safety risks if the guidelines below are not followed:
Accumulate different waste types in separate containers (solids vs. liquids, solvents vs. oil, oil-based paint vs. latex paint). This simplifies tracking of waste constituents in each container for labeling purposes, reduces the risk of reaction between incompatible wastes, and avoids costly generation of excess regulated hazardous waste from potential mixing of non-hazardous wastes with hazardous wastes.
When possible, avoid reusing plastic containers for liquid waste other than containers provided by or approved by EHS. Plastic breaks down over time especially when exposed to adverse weather conditions.
Choose an accumulation container size that fits the quantity of waste that you will generate in a reasonable amount of time.
4. Manage containers in accumulation areas properly – Good management of containers
in waste accumulation areas increases safety for everyone involved in handling and
transporting waste chemicals. All requirements in Attachment B in addition to the following
must be practiced to ensure safety and compliance:
Label containers with an accurate description of their contents.
Keep containers closed at all times unless you are actively adding or removing waste.
Keep containers free of contamination on the outside.
Check containers for corrosion, leaks or other problems routinely.
Check product Safety Data Sheets (SDS) for information on ingredients and other hazard information to ensure proper storage with other materials.
Flammable liquids should be stored in approved containers. Do not store corrosive liquids in metal containers or drums.
Keep flammable waste away from ignition sources.
Only fill liquid waste containers to 90% full to allow for expansion.
Do not accumulate or store waste containers outdoors.
Do not use red biohazard bags or red sharps containers for storage of any wastes. If you have questions, call IUB EHS.
5. Package – Containers must be packaged properly to be accepted by IUB EHS.
For containers <5 gallons:
IU Bloomington Waste Management 21
Each container must have a properly completed, signed, and dated tag attached with a rubber band, twist tie, or tape.
The tag must list all of the ingredients of the waste and their percentages. The percentages must add up to 100%. No acronyms or abbreviations should be used on the tag.
An SDS may be attached to the container along with the tag if the waste is a chemical product and you do not know all of the ingredients.
Every effort must be made to ensure that waste containers are sound and that lids are tight sealing, even if that means the waste must be repackaged. If a problem with a container cannot be resolved, the container must be placed into an individual bucket with a lid, and the outside of the bucket must be labeled the same as the container would be. IUB EHS can provide buckets with lids as needed.
For containers >5 gallons (drum quantities):
Ensure bungs are tightened, lids are secured, and there is no bulging from pressure build-up. Contact IUEHS before requesting a pickup for any containers that are missing bungs or have lids that cannot be secured.
Each drum must have a properly completed Hazardous Waste Label or Waste Chemical Tag unless otherwise indicated in this Guide or by EHS.
If the waste pickup area cannot be accessed with a drum cart, or is only accessible by stairs, waste must be stored in 5 gallon containers or smaller so that they can be carried out.
6. Dispose – Once a waste accumulation container is full or an unused chemical has been
determined to be a waste, it should be transferred to IUB EHS for disposal as soon as
reasonably possible. Keep in mind the regulatory accumulation time limits specified for
some waste types in Section 5.3, and remember that storing waste past the time limits can
result in regulatory citations for the University.
Unless otherwise indicated in this Guide or by IUB EHS, waste is picked up by IUB EHS on request during regularly scheduled pickups. See the online Waste Collection Schedule to determine when to expect a pickup after making a request. Once a waste is ready for disposal, ensure that it is packaged, labeled or tagged and dated. Then request a pick-up.
Dispose of waste in a timely manner. IUB EHS offers ample opportunities for disposal. Safety and compliance is maximized when waste is disposed on a regular basis.
At the time you offer your waste for pickup, make sure that it is properly packaged and labeled. Problems must be corrected by the generator before IUB EHS will accept the waste. Call IUB EHS before you are ready to transfer waste if you have any questions or need assistance.
This section explains the disposal options for solutions of acids, such as hydrochloric, nitric and sulfuric
acid, and bases such as ammonium sodium hydroxide from laboratories. It is best to dispose of
concentrated solutions of acids or bases with IUB EHS due to the difficulty of neutralization. Use only
disposable containers for waste that will not be neutralized because these containers will not be
returned to you. Wastes that have been pre-approved by IUB EHS for neutralization following the
neutralization procedures outlined in Section 4.1 are listed in Attachment A. If a material that you want
to neutralize is not listed in Attachment A contact IUB EHS for approval.
1. Concentrated acids
<25 ml and approved for sewer disposal in Attachment A - Follow neutralization procedures in Section 4.1 or dispose directly with IUB EHS.
>25 ml or not approved for sewer disposal – Dispose directly with IUB EHS.
2. Dilute acid solutions or concentrated or dilute base solutions with no toxic metals
Approved for sewer disposal in Attachment A - Follow neutralization procedures in Section 4.1 or dispose directly with EHS.
Not approved for sewer disposal – Dispose directly with IUB EHS.
3. Dilute acid solutions or concentrated or dilute base solutions containing toxic metals
Dispose directly with IUB EHS. All toxic metal ingredients must be identified on the Waste Chemical Tag. Many toxic metals are regulated hazardous wastes at very low concentrations, and IUB EHS must make that determination. See Aqueous Solutions of Toxic Metals for a list of metals that cannot be sewer disposed.
Note: Nitric and perchloric acids are not approved for neutralization or consolidation at any concentration.
Aerosol Cans
Aerosol cans are pressurized, and often contain flammable propellants. Even empty aerosol cans
remained slightly pressurized, and should not be thrown away. Refer all aerosol cans to IUB EHS for
chemical waste disposal. An exception to this would be non-flammable compressed air dusters, which
can be discarded as general refuse, after consulting the SDS for the material to ensure the air duster
does not contain flammable propellants. All aerosol cans for disposal with IUB EHS must have a
completed tag or date label.
Air and Water Reactive Materials
Dispose of all air and water reactive materials, such as those listed below, through IUB EHS. Package any
liquids separately from solids and note any special hazard and/or handling precautions on the Waste
Chemical Label or tag.
Acetyl chloride Lithium metal Sodium metal
Bromine Phosphorus (yellow) Thionyl chloride
Calcium metal Potassium metal Trichlorosilane
Animals and Animal-Related Materials
Refer to the IU Biosafety Manual for disposal procedures for animals and animal-care-related materials.
Note: For any solutions containing mercury, the Waste Chemical Tag. must indicate whether the mercury
concentration is less than or greater than 260ppm. If you are unsure, assume >260ppm.
Ballasts
There are three types of lamp ballasts in use at IUB:
PCB Ballasts
Polychlorinated biphenyls (PCB) containing ballasts are regulated by the Toxic Substances Control
Act (TSCA), and must be collected by IUB EHS for disposal. These ballasts are hazardous because of
the toxic fluid inside. PCB ballasts are found in older lighting fixtures. Lighting fixtures in campus
buildings have been systematically upgraded over the last several years. When the fixtures are
upgraded, they no longer use PCB ballasts. Eventually there will be no more PCB ballasts on campus.
IUB EHS will supply drums for collection of PCB ballasts. Employees must ensure that the drums are
properly labeled (see Attachment D) and dated. Date drums as soon as the first ballast is added.
PCB ballasts are required to be disposed of within one year from the time that they are removed
from service. Call IUB EHS to pick up the drum as it approaches 9 months old even if it is not full so
that the disposal time limit is not exceeded.
Non-PCB Ballasts
Non-PCB ballasts can be disposed in the regular trash or salvaged for scrap metal if an outlet is
available. IUB EHS does not collect these ballasts.
Electronic Ballasts
Electronic ballasts are essentially non-PCB ballasts that contain a Ni-Cd battery. The batteries must
be removed and disposed through Facility Operations. These ballasts can be disposed in the regular
trash or salvaged for scrap. IUB EHS does not collect these ballasts.
IU Bloomington Waste Management 24
Batteries (Universal Waste)
IUB EHS has chosen to manage all batteries as Universal Waste. There is a separate recycling exemption
that applies to lead acid batteries only, and alkaline batteries are non-hazardous. From a practical
standpoint, though, it would be impossible to get the University community to sort their batteries
consistently enough to rely on, and there is not enough cost or regulatory burden savings to justify
managing them separately.
See Universal Waste for more information.
General Rules for Universal Waste Batteries:
(A printable guidance document is available at the EHS website.)
Batteries should be in good condition and non-leaking. If there is visible evidence of corrosion, they must be placed in a closed container (a lid with a hole is not considered closed). This is a regulatory requirement. If there is no visible evidence of corrosion or leaking, a lid is not required on the container.
Each battery or container must be marked with the words “Universal Waste” and a description of the material such as “used batteries”, or “spent batteries” as soon as it is collected or the first battery goes into the container. A printable label template is available online at http://www.ehs.iu.edu/topics/waste-management/chemical-waste/waste%20label%20templates.shtml.
Each battery or container must be marked with the date that it was collected or the first battery went into the container.
Each battery or container must be shipped offsite to an authorized Universal Waste handler for disposal before one year from the date marked to avoid violation of the regulations.
Battery Disposal at IUB
Facility Operations manages battery disposal at IUB. Building Services maintains battery-
recycling containers around campus for employees and University community members to use.
These containers must be managed according to Universal Waste rules as soon as the first
battery goes into them no matter where they are located on campus. IUB EHS may inspect any
of these areas periodically to insure compliance with the regulation. Contact Building Services
for a recycling container or for more information.
Note: While EHS does not manage the accumulation and collection of batteries at IUB, we do provide oversight of the Universal Waste program. We may inspect any accumulation areas and require corrections to packaging and labeling if they do not meet the regulatory requirements. We also provide training to departmental personnel.
Biological Materials
Refer to the IU Biosafety Manual for disposal procedures for biological materials.
Cardboard
Cardboard recycling at IUB is part of the larger recycling effort coordinated by Building Services and the
Office of Sustainability. “Cardboard Only” dumpsters are located at the receiving docks of many campus
buildings. A Recycling FAQ is available on the campus sustainability website.
Cardboard that is grossly contaminated with chemical(s) that exhibit flammable, corrosive, reactive
and/or toxic characteristics should be placed in a sealed container and disposed through IUB EHS
following the general procedures in Section 5.1.
Chemical Waste
Since IUB EHS determines which chemicals are regulated as hazardous waste, all unwanted chemicals
should be managed as hazardous waste when discarded unless specific instructions in this Guide or from
IUB EHS personnel state otherwise (See Section 2). Areas that generate hazardous chemical waste must
follow the Satellite Accumulation Area Requirements in Attachment B as well as all IUB EHS general
requirements for waste management in Section 5 of this Guide. Discard chemical waste often to avoid
deterioration of containers and labels. Waste must be removed from your satellite location within 3
days if you accumulate more than 55 gallons. This is a regulatory requirement. Waste pickups can be
requested at http://apps.ehs.iu.edu/waste/main.cfm.
Laboratory Operations
Follow all general requirements in Section 5.1 for any chemicals or chemical wastes to be
discarded, and check Section 5.3 for any additional requirements for specific waste types.
Non-Laboratory Operations
Non-laboratory chemical waste may be generated by maintenance, custodial, landscaping, or
other facilities operations. Common examples include:
Aerosols and cylinders such as propane tanks;
Cleaning compounds (many are corrosive);
Pesticides with toxic ingredients;
Mercury and mercury debris;
Paints (oil based), solvents, stains and adhesives;
Pool or water treatment chemicals;
Fuels and fuel/oil mixtures; and
Spill debris from hazardous chemical spills.
Follow all general requirements in Section 5.2 for any of the above materials or any other chemical product to be discarded, and check Section 5.3 for any additional requirements for specific waste types.
Chemically Contaminated Items (CCIs)
Chemically contaminated items (CCIs) such as disposable labware and gloves, bench top coverings,
pipets, test tubes, aprons, etc. can be put into the normal trash if they are not reactive, ignitable,
infectious, or radioactive; the contaminant is not highly toxic; and the material will not cause a nuisance
or physical hazard when placed in the trash. If your CCI contaminant is not listed in Attachment A and
you are unsure whether normal trash is an appropriate disposal route for your CCIs, contact IUB EHS for
approval prior to disposal.
If your CCIs cannot be placed in the normal trash for one of the above reasons, package them in a 5-
gallon-size plastic bag, at least 2ml thick (obtained through the Chemistry or Biology stores). These bags
can be placed conveniently inside a 5-gallon plastic bucket for in-lab accumulation. Remove the bag
from the bucket and close it with a rubber band, twist tie, zip tie, or by tying the top when it is full. Label
the Waste Chemical Tag as "chemically contaminated items" or "CCIs" and list all chemical
Aerosols Any Aerosol can Tag and dispose with IUB EHS.
*Due to the high disposal costs of many materials purchased in cylinders and Sure-Packs, EHS charges the cost of disposal for these items back to the generating department. It is up to each department whether to pass that cost back to the individual researchers. **Because lease/maintenance and return agreements for returnable cylinders are generally arranged and maintained by parties outside the purview of EHS, if those agreements are abandoned and EHS must arrange disposal or return of these items – costs are charged to the generating department. It is up to the department to decide if they want to pass that cost back to the individual researcher or not.
Ethidium Bromide
Ethidium bromide is a strong mutagen that, in its pure powder form, is also highly toxic by inhalation.
Although solutions at the concentrations typically used in electrophoresis are relatively low toxicity,
ethidium bromide preparations including stock solutions and gels are collected by IUB EHS for disposal
as chemical waste.
Solutions, gels, and contaminated solids such as filter paper, gloves, and pipette tips, must be
accumulated separately. Solutions and gels must be accumulated and disposed in rigid containers, while
contaminated solids may be accumulated in plastic bags for disposal. One-gallon wide-mouthed plastic
jars and five-gallon plastic buckets are available from IUB EHS for waste accumulation.
Explosive or Shock-Sensitive Chemicals
If you have an explosive or shock-sensitive material for disposal, call IUB EHS for assistance. Many of
these materials become less stable over time or as they dry out. Therefore, they should never be stored
in a desiccator, or under any other condition that would allow for the material to dry out. Do not store
unused amounts for an extended period of time. See Section 5.4 for additional information regarding
potential charges for disposal of high-hazard materials. Potentially explosive chemicals include:
Aged peroxide forming agents,
Diazo compounds,
Dinitro compounds,
Hydrazine compounds,
Nitrocellulose,
Dry picric acid, and
Trinitrotoluene
Fluorescent Light Bulbs (Universal Waste)
Fluorescent light bulbs come in different sizes and shapes; long, straight lamps used in ballast operated
light fixtures, or compact fluorescent bulbs used in place of incandescent bulbs. All fluorescent bulbs or
lamps contain a small amount of mercury. Bulbs known as “green” or “green tip” contain mercury in
low enough amounts to be exempt from waste regulations. They can be distinguished from higher level
mercury bulbs by their green endcaps or other markings. Bulbs that are not “green” must be managed
as Universal Waste. Collecting green lamps along with regular lamps for Universal Waste recycling is
encouraged, but not required. Bulbs that are not “green” must be managed as Universal Waste.
See: Universal Waste for more information.
General Rules for Universal Waste Bulbs:
(A printable guidance document is available at the IUB EHS website.)
All used bulbs must be stored in a closed container to protect against breakage as soon as they are collected.
· Use boxes that the bulbs came in or round fiber drums provided by the disposal vendor. Make sure to use a box or drum that is long enough to fully cover the entire length of the bulbs in the container. Fill containers carefully to avoid breaking bulbs.
· Each container must be marked with the words “Universal Waste” and a description such as “Used Bulbs” or “Used Lamps” as soon as the first bulb goes into the container. A printable label template is available online at http://www.ehs.iu.edu/topics/waste-management/chemical-waste/waste%20label%20templates.shtml.
· Each container must be marked with the date that the first bulb went into the container.
· Each container must be shipped offsite to an authorized Universal Waste handler before one year from the date marked on the container to avoid violation of the regulations.
· If a bulb breaks before it is placed into a container, it is no longer a Universal Waste. The debris from the cleanup of the broken bulb must be managed as hazardous waste. Follow the general requirements set out in Section 5.2 of this Guide for management and disposal of hazardous waste.
*The bulb cleanup procedure can be found at the IUB EHS website.
Disposal of Fluorescent Bulbs at IUB by location:
Facility Operations - bulbs from fixture lighting in areas maintained by Facility Operations are collected, stored, and shipped by Building Services and Zone Maintenance personnel.
Residential Programs and Services (RPS) - bulbs from fixture lighting in areas maintained by RPS are collected, stored, and shipped by RPS personnel.
All other areas or buildings at IUB - bulbs from fixture lighting from all other areas aside from Facility Operations and RPS must be collected and stored according to the rules above for Universal Waste bulbs. Offsite shipping arrangements must be made by the department or contractor responsible for the area or building, and shipping documents must be available to IUB EHS upon request.
IUB EHS – specialty bulbs from any campus location, including bulbs from specialized fixtures such as some outdoor lighting, sodium discharge lamps, high intensity discharge lamps, and mercury vapor bulbs, are managed by IUB EHS. Package and label bulbs according to the general rules for Universal Waste bulbs and request a pickup from IUB EHS within 9 months.
Note: While EHS does not manage the storage and disposal of all bulbs at IUB, we do provide oversight of the Universal Waste program. We may inspect any accumulation and storage areas and require corrections to packaging and labeling if they do not meet the regulatory requirements. We also provide training to departmental personnel.
General Refuse (Trash)
Non-recyclable, non-hazardous refuse (trash) should be placed in designated area trashcans or
dumpsters. Liquids and semi-liquids are prohibited from disposal in campus dumpsters and compactors.
Broken glass must be placed into a rigid cardboard box and clearly marked with the words “BROKEN
GLASS”.
Treated biological waste containers must have autoclave indicator tape placed on them in order to
confirm they were autoclaved prior to disposal in the general trash. Biohazard symbols must be
Note: The Universal Waste exemption does not apply to metallic mercury that is not contained in a
device or to mercury-contaminated debris.
See Universal Waste for more information.
General Rules for Universal Waste Mercury Devices:
(A printable guidance document is available at the EHS website.)
Devices and equipment must be placed in containers such as buckets or drums provided by IUB EHS, or in boxes that can be closed securely.
Mercury must not be leaking from the equipment.
Containers must be closed at all times when a device is not being added.
Containers must be labeled with the words “Universal Waste – mercury-containing equipment” and the date that the first item was added. A printable label template is available online at http://www.ehs.iu.edu/topics/waste-management/chemical-waste/waste%20label%20templates.shtml.
Each container of mercury-containing equipment being managed as Universal Waste must be shipped off campus to an authorized Universal Waste handler before one year from the date marked on the container to avoid violation of the regulations.
Disposal of Mercury Devices at IUB:
EHS manages the off-site disposal of mercury-containing equipment. In order to insure that
containers are shipped off campus before one year to remain in compliance with regulations,
pickups must be requested for all containers once their dates reach 9 months. Pickups can be
requested online at the IUB EHS website. EHS may inspect accumulation areas periodically to
insure compliance with Universal Waste requirements.
Mixed Waste
Mixed wastes are those that pose multiple hazards including biological, chemical and/or radiological.
Handling and disposal of mixed wastes can be complex due to overlapping regulatory requirements and
restrictions imposed by treatment facilities. IUB EHS cannot dispose of waste that is radioactive, or that
poses both chemical and biological hazards.
Radioactive Mixed Wastes
In general, if a mixed waste is radioactive it must be decayed in-lab according to IUB Radiation
Safety protocols first. If you will be generating a radioactive mixed waste with a long-lived isotope,
you must contact IUB EHS before you begin generation or as soon as you know you have it if it was
unintentional. All waste containers must be fully and accurately labeled with the date of generation,
the isotope, and the chemical or biological components.
Biological and Chemical Mixed Wastes
Wastes that contain a mixture of both biological and chemical components must be evaluated to
determine if the chemical in the waste has deactivated/disinfected all biological hazards present. If
not, the generator must add an adequate volume of an approved disinfectant or fixative that is
chemically compatible with the waste such as ethanol, bleach, formalin, etc. The generator of the
waste must certify that it has been disinfected, and communicate with IUB EHS the type and volume
Most chemical waste is handled by IUB EHS. However, you might have some nonhazardous waste
listed as acceptable for sewer or trash disposal in Attachment A of this Guide.
Chemicals (liquids and solids) can be flushed to the sanitary sewer if they are:
water soluble,
degradable in the sanitary sewer system, and
non-toxic.
Solid chemicals or spill clean-ups that are not water soluble, but are non-toxic, and do not present
any other safety hazard or nuisance, can be disposed in the regular trash. All chemicals poured into
the sewer must be followed by at least 20 parts water.
Notes: If you intend to dispose of more than one liter of a non-hazardous liquid or 5 pounds of solid, or if the material is not listed in Attachment A of this Guide, contact IUB EHS for pre-approval.
Non-Laboratory Operations
Some materials are not hazardous, but still cannot be disposed directly into the trash because of
landfill restrictions. The most common restriction encountered is that liquids and semi-liquids are
not allowed to be landfilled. Many oils, latex paint, and other water-based materials are non-
hazardous and could be landfilled if they were solid, but cannot be when they are liquid.
Spill debris from non-hazardous wastes can be discarded in the trash, as long as all free liquid is
absorbed. Minimal amounts of liquid in otherwise empty containers of non-hazardous wastes can
be absorbed with kitty litter or other suitable absorbent material and disposed in the trash also.
Common examples of non-hazardous chemical waste include:
Antifreeze and other glycols;
Latex paint;
Non-toxic pesticides (such as dormant oil), fertilizers and plant food;
Oils (non-PCB) and cutting fluid; and
Water-based coatings, detergents and surfactants.
Oil
Various types of oil, including vacuum pump oil, motor oil, cutting oils, etc., that is not contaminated
with solvent or other chemicals, may be referred to IUB EHS for used oil management or arrangements
may be made with an approved vendor. Contact IUB EHS for approval of used oil management vendors.
Oil containers must be labeled as “used oil” while being accumulated.
Any used oil that is contaminated with other chemicals must be accurately described and disposed as a
chemical waste through IUB EHS. If the oil contains PCB, the generator must indicate such on the label
and as part of the chemical description on the waste pick-up request form. The concentration of PCB in
parts per million (PPM) should also be listed if known. Oil containers must be labeled as “used oils”
while being accumulated.
See also: Polychlorinated Biphenyls, Vacuum Pump Oil
IU Bloomington Waste Management 33
Paint and Paint Products
Latex paint that is still in good condition, even if the container has been opened, should be referred to
Surplus Property for re-distribution or sale. Paint that is no longer useable, contains lead, or is oil based,
as well as spray paint, must be referred to IUB EHS for chemical waste disposal. For lead-based paint
chips, see: Lead.
Peroxide-Forming Agents
Peroxides are low power explosives and are very sensitive to shock and heat. A variety of organic
compounds react with oxygen from the air to form unstable peroxides. One of the following conditions
must be met before peroxide formers may be accepted by IUB EHS for disposal. These are requirements
enforced by our disposal contractor, as well as good laboratory safety practices.
The material must be less than twelve months old. This information must be marked clearly on the Waste Chemical Tag.
If the material is greater than twelve months old but less than two years old, check for peroxide formation by using peroxide paper stocked at Chemistry Stores. If peroxide formation is less than 100 ppm, add 1 tsp. of hydroquinone per pint of material to prevent the formation of additional peroxides. Mark this information on your waste tag (e.g., "<100 ppm, hydroquinone added") and bring it to an Open House. If peroxide formation is greater than 100 ppm, call IUB EHS for technical assistance.
If the material is greater than 2 years old but less than 5 years old, it should be assessed for other factors such as: duration of exposure to sunlight, volume of container (i.e., "Is it full?"), security of the seal, exposure to changes in temperature, etc. If you do not know the answer to any of these questions, find someone who does. Do not open the container to check for peroxide formation, as the material could be shock-sensitive. Call IUB EHS for technical assistance.
If the container is more than five years old, do not move the container at all. Post a sign reading "DANGER: possible shock-sensitive chemical" and call IUB EHS for technical assistance.
Safety Tips for Peroxide Formers
Date peroxide formers when received and when first opened. In general, discard according to time
limitations suggested by the manufacturer. For severe and high peroxide formation hazard
chemicals, the storage limitations are:
Avoid exposure to light or air and store in light-resistant containers.
Refrigeration does not prevent peroxide formation.
As is the case with all hazardous chemicals, order only those amounts that you need.
Do not move or attempt to open containers of unknown age. An obvious indicator of peroxide formation is evidence of needle-like structures or crystals in the liquid. However, dangerous peroxides may be present without obvious crystal formations. Peroxide crystals may have formed on the cap and threads. Call IUB EHS for assistance.
Never distill peroxide-forming solvents.
See also: Explosive or Shock-Sensitive Chemicals
Pesticides
See Chemical Waste.
Pharmaceuticals
Prescription, over the counter, and research drugs should be referred to IUB EHS for disposal. See:
Controlled Substances for disposal of DEA scheduled materials.
Picric acid
In its solid form, picric acid can be explosive if it dries out sufficiently. Never store solid picric acid in a
desiccator. See: Explosive or Shock-Sensitive Chemicals for disposal information.
Dilute solutions of picric acid are not explosive, and may be disposed as chemical waste. (See: Chemical
Waste).
Polychlorinated Biphenyls (PCBs)
PCBs are synthetic chemicals manufactured until 1979 when they were banned in the United States.
PCBs can be found inside heat transfer systems, hydraulic systems, transformers and lighting ballasts
manufactured before that time. IUB EHS must collect and dispose of PCB containing fluids, equipment,
research chemicals and contaminated debris. If you need to dispose of equipment that contains oil,
dielectric fluid, hydraulic fluid or other potential sources of PCBs, please note the date that the
equipment was taken out of service, and any information that can help EHS determine the date the
equipment or fluid was manufactured. If fluid suspected of containing PCBs has leaked from equipment,
follow campus emergency procedures to report a chemical spill immediately. See also: Ballasts, Oil
Radioactive Waste
All radioactive materials and waste must be handled and disposed in accordance with the IU Office of
Radiation Safety policies and procedures. More information can be found at
Refrigerants such as Freon® must not be released into the atmosphere, and must be properly removed
from equipment such as air conditioners, refrigerators and freezers. At IUB, refrigerant reclamation is
managed by Facility Operations.
Sharps
Various sharps are generated on campus, such as needles, razor blades, and broken glassware. Although
most are not regulated as hazardous waste, they do require special handling for safety reasons.
Regardless of contamination, sharps must be placed in appropriate, rigid containers that guard against
puncture and injury (no Ziploc bags), and labeled as “sharps” prior to disposal unless your building
procedures specifically allow for alternative handling. Manage sharps in the following manner:
Chemically contaminated sharps that are grossly contaminated with hazardous chemicals must be collected in puncture-resistant containers, marked as “sharps contaminated with “______________”, and sealed tightly. These sharps should then be disposed through IUB EHS.
Biohazard sharps: Metal and glass sharps contaminated with biological materials must be packaged and disposed according to procedures outlined in the IU Biosafety Manual.
Radioactive sharps: Metal and glass sharps contaminated with radioactive materials must be packaged and disposed according to procedures outlined in the IUB Radiation Safety Manual.
Uncontaminated metal sharps must be packaged in puncture-resistant containers, labeled as “nonhazardous waste sharps”, and sealed tightly. Dispose in the normal trash.
Uncontaminated glass sharps must be packaged in a puncture-resistant container, labeled as “nonhazardous waste sharps”, and sealed tightly. Dispose in the normal trash. These sharps may be placed directly in glass dumpsters with no special labeling or container requirements, if one is available at your building. This category includes sharps that are minimally contaminated with non-reactive chemicals.
Note: Sharps containers are sold in chemistry stores, the biology stock room and lab supply catalogues. Red biohazard sharps containers are prohibited. Clear sharps containers with a biohazard symbol should be used for biohazard sharps and green or blue containers or white buckets should be used for nonhazardous sharps.
Packaging, Labeling, and Disposal of Sharps Waste
Contamination
Type Package Labeling Disposal
Biological See IU Biosafety Manual. See IU Biosafety Manual. See IU Biosafety Manual.
Amorphous silica gel is widely used at IUB as column packing media, especially in the Chemistry
department. IUB generates approximately one ton per year of used silica gel. IUB EHS has determined it
to be nonhazardous, but it is dusty and has a nuisance odor if disposed in the dumpsters. Therefore, it is
required to be disposed through IUB EHS.
Used silica gel can be accumulated in 5 gallon plastic buckets or 1 gallon plastic jars depending on your
rate of generation. IUB EHS has containers available during waste collections or by request to be
delivered at the time of waste pickups. Store all containers closed and label "waste silica gel." Only gel
should be accumulated in these containers – no plastic wrap, instruments, gloves, bench paper, or other
debris.
Note: If you use pyridine in your chromatography procedure, you must separate the silica gel from that
procedure from any other silica gel that you generate, and indicate pyridine as a component of the waste
on the Waste Chemical Tag.
Sodium Azide
See: Explosive or Shock-Sensitive Chemicals
Solvents (Laboratory operations only)
Due to the large volume of organic solvents generated at IUB, EHS consolidates these materials from the
small containers received from numerous laboratories into large drums to be shipped to off-site waste
vendors. This results in a significant cost-savings for the University as well as addressing safety,
compliance, and convenience issues in the labs. To facilitate this program, you must follow the
procedures below.
Safety Can Use
Place your organic solvents in a safety can. The safety cans are reusable. They will be emptied by IUB EHS and returned to you. Very small generators can use other containers if a safety can is not practical. Be mindful of the fill line on the can. It is difficult to pour liquid from an overfull can without spilling.
Label your safety can with the words “hazardous waste” and some description of the contents as soon as any waste is put into them. This is a regulatory requirement. IUB EHS can provide a Hazardous Waste Label (Figure 5B) for this purpose.
Start a waste tag or a content log for your safety can or container as soon as the first material is added to it so that you will be able to account for 100% of the chemical composition of the container.
Waste must have a pH between 3 and 11 or it will be rejected. Because we are comingling your waste with other solvents, we need to ensure compatibility using pH as a gauge.
IU Bloomington Waste Management 37
Note: Safety cans with broken springs or other defects make them no longer operable as safety cans. Inoperable cans will not be returned. Safety cans are to be used for solvents only. The following should NOT be placed in your safety cans in any concentration:
Acid and base solutions - If you have large volumes of solvents with low or high pH, you may use safety cans and neutralize the waste before offering to EHS according to the neutralization procedures outlined in Section 4 of this Guide. Waste with a pH less than 3 or greater than 11 at the time it is presented for disposal may be rejected. Also, be sure to allow 24 hours after neutralization before disposal to insure that the pH has stabilized and the heat of reaction has dissipated. Note: If a solution is warm to the touch when presented for disposal in a reusable container, it may be rejected or you may be asked to leave the container until the next waste collection.
Aqueous solutions of toxic organic chemicals - If your procedures are such that water is mixed with solvents during the course of a reaction, it is okay to put in a safety can with other solvents. Do not add primarily aqueous solutions to solvents in a safety can.
Reactive substances – This includes air and water reactive chemicals, as well as materials that are known to react badly with organic solvents.
Unknowns
Stench compounds – Safety cans are to be poured in our processing area using local exhaust, and returned to you while you wait. Stench compounds which include all sulfides, thiols, mercaptans, some amines, butyric acid, valeric acid, etc., overwhelm the exhaust system. Odors accumulate in the processing area and can escape into the general building ventilation. Safety cans with stench compounds will be taken for disposal without return. If you have a safety can that contains stench compounds, and you want to keep it, IUB EHS can provide a 5-gallon bucket that you can take back to your lab and use your fume hood to transfer the contents. These wastes will not be poured in the IUB EHS waste processing area.
Solvent-Contaminated Wipes
Wipes and rags contaminated with solvents are subject to hazardous waste exemptions in certain
circumstances. Wipes and rags contaminated with common solvents like turpentine and mineral spirits
may be disposed in the regular trash as long as they are not dripping liquid.
Note: Waste wipes and rags that contain solvents, oil based paints or oils should be placed in a covered
metal container and taken to a dumpster at the end of each day to minimize odors and accumulation of
combustibles.
Wipes and rags contaminated with one or more of these solvents:
must be collected and accumulated according to the following guidelines:
They must be accumulated in your area in non-leaking containers that are closed at all times except when wipes and rags are being added.
The accumulation containers must be labeled with the words “excluded solvent-contaminated wipes” or with other words that accurately describe the container contents.
The containers must be shipped off-site for disposal within 180 days of the date that the first wipe or rag was placed in the drum. To ensure that this time limit is being heeded, IUEHS requires the containers to be dated when the first material is added, and for the containers to be transferred to IUEHS or to a reusable wipe/rag laundry service within 5 months.
Wipes and rags must not contain free liquids when they are offered for disposal.
If you use a laundry service for reusable wipes or rags, you must maintain the following information and make it available to IUEHS for inspection:
o Name and address of the laundry service.
o Shipment records showing that the 180-day accumulation time limit is being met.
o A description of the process that you use to make sure that the wipes or rags contain no free liquids when shipped off-site.
Spill Debris
For liquid spills that meet all of the reporting exception criteria listed in Section 8 of this Guide, absorb
with spill pads, disposable towels, or other absorbent material and place them into a sealed container or
leak resistant bag. After absorption, use a small amount of soap and water to clean spill surfaces and
dry thoroughly. For solids, sweep up the spill with a broom and dustpan. Collect the material into a
plastic or glass container or Ziploc® bag. Do not use a shop vac or vacuum cleaner.
For inert, non-hazardous chemical spills, place in a sealed container, including the broken chemical container, contaminated towels, etc. for general trash disposal. Be sure all liquid spills are fully absorbed into the absorbent material.
For spills involving material that must be collected by IUB EHS, the debris must be placed in a closed container with a Waste Chemical Tag described as “Spill debris containing _______.” with the identity of the material that was spilled filled in.
Universal Waste
Some waste materials meet the definition of a hazardous waste, but the EPA provides an
exemption if they are destined for recycling. These wastes are referred to as Universal Waste.
They are subject to less stringent documentation and recordkeeping requirements as well as
extended accumulation time limits. Generators of Universal Waste must still comply with rules
for accumulation including segregation, labeling, and container management. See Fluorescent
Bulbs, Batteries, and Mercury-Containing Devices for specific requirements for each waste
type. IUEHS has chosen not to use the available Universal Waste exemption for hazardous
pesticides because it does not have any significant effect on the University’s regulatory burden
or costs. Hazardous pesticides, and those that are non-hazardous such as dormant oils and
insecticidal soaps, should be managed as chemical waste.
IU Bloomington Waste Management 39
Attachment D contains some sample examples of labels that can be used to meet the labeling requirements. IUB EHS also has printable label templates available online at http://www.ehs.iu.edu/topics/waste-management/chemical-waste/waste label templates.shtml.
Note: Spill debris from Universal Waste must be managed as a hazardous chemical waste through IUB EHS.
Unknowns
Unlabeled or poorly labeled containers of chemicals or products in areas where hazardous materials are
used or stored represent serious legal and safety problems for the University. They must be assumed
hazardous unless evidence or certification to the contrary can be obtained.
Without an accurate description, it is difficult to characterize the hazards presented and dispose of the
material legally and safely. Disposal companies will not accept chemical waste without an analysis or
specifically defined characterization of hazards.
It is the responsibility of the person generating a waste to accurately keep track of the contents of
containers so that the material can be described adequately for the disposal vendor when it is
discarded. If proper labeling and records on containers are not maintained and an adequate description
cannot be provided; or if the disposal company requires further analysis, EHS will charge-back the
generating department. See Section 5.4 for additional information.
Vacuum Pump Oil
Uncontaminated vacuum pump oil should be referred to IUB EHS for recycling. Contaminated vacuum
pump oil should be marked or labeled as a waste chemical with the words “Used Pump Oil” and, if
known, “contaminated with (list all known chemical contaminants)”. See also: Oil
IUB EHS charges auxiliary and administrative departments for the direct disposal costs of waste
that they generate. Under normal circumstances, IUB EHS does not charge for the cost of waste
handling and disposal services for academic or research groups. However, IUB EHS reserves the
right to charge the department of any waste generator who incurs regulatory fines as a result of
non-compliance with this Guide, or who requires services that result in significant costs to IUB
EHS or to the University as a whole. Services that commonly result in charges include:
Cylinder Disposal: Many cylinders can be returned to the manufacturer for refill or recycling in quantities as low as 1lb. In most cases, disposable cylinders (non-returnable) with remaining pressure, product or product residue must be referred to IUB EHS for waste disposal. Empty cylinders can only be discarded as general refuse or scrap metal if they once contained an inert, non-toxic gas and are proven to be at atmospheric pressure by valve removal or puncture. IUB EHS reserves the right to charge back special handling or disposal charges incurred per disposable cylinder to the responsible department. Check with your department representative for returnable options before purchasing a disposable cylinder.
High-Hazard Waste Disposal: Unstable, reactive or peroxide-forming chemicals that are improperly stored, mixed with incompatible materials or otherwise mishandled can pose serious risks, including fire or explosion. Due to the high-hazard nature of these materials, IUB EHS must contract special services for stabilization, transportation and disposal at an extremely high cost. IUB EHS reserves the right to charge back for specialized high-hazard waste management services per container.
Laboratory Chemical Moves: Personnel must comply with campus specific guidelines for inter and intra-building chemical moves found in the IU Hazardous Materials Transportation Program. The program provides detailed procedures for notification of IUB EHS, timeframes, and preparation of materials. Preparation and move assistance from IUB EHS personnel is also available with adequate notification for a fee that includes time and materials. Responsible departments must ensure that guidelines are followed so that all chemicals, wastes, and contaminated items are identified and managed properly before a lab is vacated. IUB EHS charges the responsible department for any unreasonable costs incurred for the cleanout of labs that do not comply with the proper procedures.
Mercury Disposal and Spill Response: As part of the University’s waste minimization effort, and due to the high cost of disposal, all non-essential uses of mercury are prohibited at Indiana University. Authorization for essential uses of mercury and/or mercury compounds must be obtained from IUB EHS. Details are outlined in the Mercury Reduction/Elimination Program. Charges related to disposal and/or spill cleanup of unauthorized mercury will be referred back to the generating department.
Unknown Fingerprinting: All chemical materials must be fully identified and labeled by the generator with adequate information for IUB EHS to determine potential hazards and a proper disposal method. Unidentified chemicals are expensive to dispose, and dangerous to emergency responders. IUB EHS reserves the right to charge the responsible department for each container of unknown material. The amount charged is determined by IUB EHS based on the cost of characterization and disposal. To avoid these charges, trained laboratory personnel may opt to perform their own unknown fingerprinting for unknowns <5 gallons in size using the IUB Unknown Characterization Procedure.
The success of the IU Waste Management Program depends on the cooperation and conscientious
efforts of everyone at IUPUI. IUPUI EHS collects a wide range of chemical waste from laboratories,
shops, offices, etc. for off-site treatment or disposal. This section outlines the general procedures for
managing waste from laboratory and non-laboratory operations on the IUPUI campus. Waste handling
and disposal protocols for specific waste types commonly generated by both of these operations, is also
included. The procedures and methods provided must be followed to ensure your health and safety, as
well as regulatory compliance. If you have any questions, contact IUPUI EHS immediately.
6.1 IUPUI Laboratory Waste Management The following general requirements apply to waste generated by laboratory operations.
Laboratories generate a large variety of waste types. Those waste types should be managed as
hazardous waste, unless otherwise specified by this Guide or IUPUI EHS staff.
General Requirements:
1. Identify and label – Note: All waste containers must be labeled! Containers are to be labeled at the time the first waste is added, and subsequently add constituent names as needed.
Chemicals in original containers with intact labels do not need to be relabeled unless they are difficult to read. Small bottles may be labeled by any means which completely identifies the contents of the bottle, such as placing the small container(s) in a labeled, Ziploc® bag.
Pre-printed, adhesive Waste Chemical Labels are available from IUPUI EHS (see Figure 6A). These labels can also be found on the IUPUI EHS website. Or, labs can create, print and secure custom labels to the container; as long as all of the constituents contained in the waste and approximate concentration of each is provided. Avoid acronyms, chemical structures or abbreviations. Provide percentages of chemicals in a mixture, including water.
Carboys have an optional Carboy Waste Container Inventory for use with 5 gallon dump-jugs, in addition to the Waste Chemical Label. The Waste Chemical Label must be completed with a general identifying description of the waste, whereas the log should be filled out in detail as waste is added to the container. Include the inventory log in the plastic sleeve found on carboy when the container is full, and ready for IUPUI EHS pick-up.
2. Ensure waste containers are appropriate and in sound condition – Wastes collected by IUPUI EHS are transported within buildings and on University streets. Therefore, chemical waste must be packaged in containers suitable for transportation. Acceptable waste containers for common chemicals are as follows:
Flammable and halogenated solvents: Four-liter glass solvent bottles, one or five-gallon size metal cans or plastic carboys, or any original solvent container;
Strong acids and bases: Glass or compatible plastic bottles up to 4 liters in volume, original bottles preferred;
Miscellaneous organic and inorganic reagents: Original containers or their equivalent.
Do not use biohazard bags for storage of chemical waste.
Notes: Contact IUPUI EHS for approval to use waste containers larger than 5 gallons in size. All containers should be approximately 90% full and must have tight sealing caps or lids (no Parafilm®). Wastes that are not packaged according to these specifications will not be collected by IUPUI EHS until corrected.
3. Segregate – Separate incompatible materials before packing them into boxes. Acids must be kept separate from bases and cyanides, organic material separate from oxidizers, etc. Refer to Attachment C for more information on chemical compatibility.
4. Box your waste – All containers must be in sound, non-leaking condition with tight fitting lids. Place containers in a single layer within each box according to how they should be segregated. Keep incompatible chemicals in separate boxes to avoid adverse reactions. If multiple boxes are used, sequentially number the boxes. If you do not have boxes to containerize your waste for pick-up, segregate the waste in an area where the containers can be safely stored until pick-up by IUPUI EHS. Request that the appropriate number of boxes be brought by IUPUI EHS staff upon pick-up when filling out the online pick-up request form.
5. Complete an online Waste Pick-up Request form – The link to this form can be found on the IUPUI EHS website at http://www.ehs.iupui.edu/waste-manifest.asp. The hardcopy version of this document is titled Hazardous Materials Manifest for Intracampus Transportation, which can be filled out and faxed to our office at (317) 278-2158. Once we have received your request, IUPUI EHS will place your waste pick-up on our service schedule. We strive to respond to all requests within 1-5 business days.
Note: IUPUI EHS may require up to 30 days to complete any large-scale clean out (over 50 containers) of laboratories or stock chemical storage areas. IUPUI EHS reserves the right to charge departments for expenses incurred from large clean outs.
6.2 IUPUI Non-Laboratory Waste Management Non-laboratory operations, such as facilities maintenance, information technology support, and
academic or administrative offices, often generate similar types of waste. This section outlines
the general requirements for managing non-lab waste materials. Additional guidance on
handling and disposal of specific waste types is found in Section 6.3.
General Requirements
1. Identify - There are several types of waste common to non-research operations including:
Aerosol cans,
Antifreeze (glycol solutions),
Asbestos-containing materials,
Ballasts (PCB and Non-PCB),
Chemical waste (Cleaning compounds, fuels, solvents, water treatment, etc.),
Compressed Gases (Cylinders),
Electronic waste (E-waste),
Lead waste (Metallic and lead paint),
Spill clean-up debris,
Universal Waste (Batteries, fluorescent light bulbs, and mercury devices), and
Unknowns (Unidentified waste)
2. Label and date - Note: All waste containers must be labeled to identify ingredients! Containers are to be labeled at the time the first waste is added, and subsequently add additional information as needed.
Used oil, PCB ballasts, and Universal Waste have special labeling requirements, and limited storage times (See Attachment D).
Chemical wastes should be managed at hazardous waste (see Section 2) unless otherwise stated in this Guide (Section 6.3).
Label all containers. The description should be specific. IUPUI EHS will provide hazardous waste labels upon request (See Attachment D).
3. Store Containers Properly. Containers must be appropriate, in good condition, and kept closed. (See also: Attachment B) Check product Safety Data Sheets (SDS) for information on ingredients and other hazard information to ensure proper storage.
Flammable liquids should be stored in approved containers and keep away from ignition sources.
Do not store corrosive liquids in metal containers or drums.
Check containers for corrosion, leaks or other problems routinely.
Keep containers closed unless adding waste.
Only fill liquid waste containers to 90% full to allow for expansion.
4. Package – Box small, compatible materials. Ensure all lids are tightly closed. For drum quantities, ensure bungs are tightened and there is no bulging from pressure build-up. Place any items with missing or broken lids, leaking containers, or other problematic items into individual buckets with lids, and label the outside of the bucket with the contents.
IUPUI Waste Management 44
5. Dispose – The link to the online request form can be found on the IUPUI EHS website at http://www.ehs.iupui.edu/waste-manifest.asp. The hardcopy version of this document is titled Hazardous Materials Manifest for Intracampus Transportation, which can be filled out and faxed to our office at (317) 278-2158. Once we have received your request, IUPUI EHS will place your waste pick-up on our service schedule. We strive to respond to all requests within 1-5 business days. Keep in mind regulatory accumulation time limits provided for some waste types, and remember that storing waste longer can result in regulatory citations for the University.
Note: IUPUI EHS may require up to 30 days to complete any large-scale clean out (over 50 containers) of laboratories or stock chemical storage areas. IUPUI EHS reserves the right to charge departments for expenses incurred from large clean outs.
Electronic ballasts contain a Ni-Cad battery that must be removed. Refer the battery to IUPUI
EHS for disposal. Discard the ballast as general refuse or salvage metal scrap. IUPUI EHS does
not collect these.
Batteries
Most batteries are regulated by the Environmental Protection Agency as Universal Waste, which are
special regulations for hazardous waste batteries designated for recycling. However, University
operations that sporadically generate spent batteries from laptops, cell phones, or other electronic
devices should: segregate batteries by type. Most batteries are marked with a symbol or abbreviation
that indicates battery type. Manage batteries in the following manner:
Alkaline – Unfortunately there is limited net value to recycling alkaline batteries. These are not regulated, and can be discarded in the general trash.
For the following battery types, tape the terminals and dispose through IUPUI EHS by submitting an online pick-up request:
Lead-acid –Follow the chemical spill reporting procedures in the IUPUI Emergency Procedures Handbook for leaking lead-acid batteries.
Lithium – Primary lithium and rechargeable Lithium-ion batteries are potentially reactive, and pose a fire hazard.
Nickel-cadmium
Nickel-metal hydride
Mercury
If collecting batteries for recycling in a container over a period of time, follow Universal Waste rules for
labeling and accumulation time limits.
Biological Materials
Biological materials, including unfixed human or animal tissue must be treated according to approved
protocols, either autoclave or chemical disinfectant, before disposal. Autoclave indicator tape must be
used, and the universal biohazard symbol must be defaced to confirm that the waste has been treated.
Biological materials and fixed tissues that are chemically treated or otherwise mixed with chemicals
must be referred to IUPUI EHS for waste disposal. More information can be found in the IU Biosafety
Manual.
Cardboard
Clean, dry cardboard boxes that have been broken down flat can be recycled in campus single-stream
recycling bins or recycling dumpsters. This includes pizza boxes that are free of food scraps. Wax
coated cartons or contaminated cardboard items are not acceptable for recycling and should be
discarded in the trash as general refuse. Cardboard that is grossly contaminated with hazardous
chemicals should be placed in a sealed container and referred to IUPUI EHS for waste disposal.
Chemical Waste
The disposal of hazardous wastes is regulated by the Environmental Protection Agency (EPA) Resource
Conservation and Recovery Act (RCRA). Consult Attachment A for chemicals that require IUPUI EHS
collection. Chemicals known to present mutagenic, teratogenic, or carcinogenic hazards as indicated on
the SDS must also be referred to IUPUI EHS for disposal. Attachment A also lists chemicals eligible for
Most chemical waste will need to be handled by IUPUI EHS. However, you might have some
nonhazardous waste, listed as acceptable for sewer or trash disposal in Attachment A of this Guide; they
can be flushed to the sewer with water or disposed in the regular trash.
Chemicals (liquids and solids) can be flushed to the sanitary sewer if they are:
water soluble;
degradable in the sanitary sewer system; and
non-toxic.
Notes: If you intend to sewer dispose a material is not listed in Attachment A of this Guide, contact IUPUI EHS for pre-approval.
Oil
Various types of oil, including vacuum pump oil, motor oil, cutting oils, etc., that is not contaminated
with solvent or other chemicals, must be referred to IUPUI EHS for recycling. Any used oil that is
contaminated with other chemicals must be accurately described and disposed as a chemical waste
through EHS. If the oil contains PCB, the generator must indicate such on the label and as part of the
chemical description on the waste pick-up request form. The concentration of PCB in parts per million
(PPM) should also be listed if known. See also: Polychlorinated Biphenyls
Paint
Latex paint that is still in good condition, even if the container has been opened, should be referred to
Surplus Property for re-distribution or sale. Paint that is no longer useable, contains lead, or is oil based,
as well as spray paint, must be referred to IUPUI EHS for chemical waste disposal. Lead-based paint
chips from construction or remediation must also be referred to IUPUI EHS for disposal.
Pesticides and Residues
Pesticides are regulated by the EPA under the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA). This regulation restricts the distribution, sale and use of pesticides. Certain “restricted use”
pesticides can only be applied by individuals who are certified and trained. Un-used pesticides and their
residues should not be thrown away or poured into the drain. All pesticides and containers with
pesticide residues must be referred to IUPUI EHS for chemical waste disposal.
Peroxide Formers
A variety of chemicals can form highly explosive peroxide compounds when exposed to air. Peroxides
are sensitive to heat, friction, impact, and light and are among the most hazardous chemicals
encountered in the laboratory. Care must be taken to prevent the formation of peroxides in these
chemicals.
Preventing the formation of peroxides is dependent on inventory control of peroxide-forming chemicals.
Most of these materials are distributed with inhibitors to drastically slow peroxide formation. These are
usually effective until the container is first opened. To prevent peroxide hazards, peroxiding-forming
chemicals should be dated both upon receipt and upon opening. These materials must also be discarded
as waste through IUPUI EHS within the recommended timeframes.
IUPUI Waste Management 52
IUPUI EHS requirements for peroxide former waste acceptance are:
The material must be less than twelve months old. This information must be marked clearly on the Waste Chemical Label.
If the material is greater than twelve months old but less than two years old, check for peroxide formation by using peroxide test strips. If peroxide formation is detected, mark the test result in parts per million (PPM) on the waste chemical label, along with the date tested. Request a waste pick-up immediately. If peroxide formation is greater than 100 ppm, immediately call IUPUI EHS for technical assistance.
If the material is greater than 2 years old but less than 5 years old, it should be assessed for other factors such as: duration of exposure to sunlight; volume of container; security of the seal; and exposure to changes in temperature. If you do not know the answer to any of these questions, find someone who does. Do not open the container to check for peroxide formation, as the material could be shock-sensitive. Call IUPUI EHS immediately for technical assistance.
If the container is more than five years old, do not move the container. Post a sign reading "DANGER: possible shock-sensitive chemical" and immediately call IUPUI EHS for technical assistance.
Safety Tips for Peroxide Formers
Avoid exposure to light or air and store in light-resistant containers.
Refrigeration does not prevent peroxide formation.
As is the case with all hazardous chemicals, order only those amounts that you need.
Do not move or attempt to open containers of unknown age. An obvious indicator of peroxide formation is evidence of needle-like structures or crystals in the liquid. However, dangerous peroxides may be present without obvious crystal formations. Peroxide crystals may have formed on the cap and threads. Call IUPUI EHS for assistance.
Never distill peroxide-forming solvents.
More information on peroxide formers can be found on the IUPUI EHS Laboratory Safety website. See also: Explosive or Shock-Sensitive Chemicals
Pharmaceuticals
Non-controlled legend (prescription), over the counter and research drugs should be referred to EHS for
disposal. See also: Controlled Substances for disposal of DEA scheduled materials.
Unwanted Indiana University property such as furniture, computers, laboratory equipment, etc. must be
referred to Surplus Property. Note: Ensure all items are free of chemicals, residues or any other
potential hazards. Deface or remove any hazard markings. Surplus also collects electronic waste (E-
waste) such as laboratory equipment, computers and printers for recycling. See Electronic Equipment
for more specific information. You can arrange a pick-up at no charge for most items, read Surplus
policies and procedures, and fill out the Surplus Pickup Request Form.
Temperature Controlled Substances
Some chemicals must be stored at constant, low temperatures to maintain their stability or integrity.
These can include organic peroxides, self-reactive solids, and highly volatile compounds that must be
kept cold in order to prevent thermal decomposition, fire and explosion, or container pressurization.
For temperature controlled substance waste disposal:
Keep the material in appropriate cold storage according to the manufacturer.
Note the required temperature range needed to maintain stability of the waste and the specific location of the waste in the Comments/Questions field found at the bottom of the Waste Pick-up Request Form.
You must store potentially flammable materials in specialized refrigerator/freezers. These materials are prohibited from storage in regular, household-type refrigerator/freezer units.
Some waste materials meet the definition of a hazardous waste, but the EPA provides an exemption for
certain materials destined for recycling. However, generators of Universal Waste must still comply with
rules for accumulation, including segregation of waste types, labeling, and time limits. IUPUI manages
fluorescent lamps and batteries as Universal Waste. See Attachment D for printable labels.
Note: Spill debris from Universal Waste must be managed as a hazardous chemical waste. See also:
Batteries, Fluorescent Light Bulbs
General Rules Management of Universal Waste Batteries
These rules apply to maintenance areas where batteries may be stored before IUPUI EHS pick-
up. The general requirements for Universal Waste Batteries are:
Inspect batteries for condition issues such as corrosion, cracks or leaking. Regulations require that leaking batteries must be placed in a closed container with tight-fitting lid. Batteries with no condition issues can be placed in an open container.
Note: Large lead-acid batteries found in vehicles and forklifts are not completely sealed at the top (they are “spillable”); thus they must be stored upright. Do not store spillable batteries outdoors or near floor drains. These batteries contain sulfuric acid. If a lead-acid battery tips over and spills, follow campus emergency procedures for chemical spills.
Label each battery or battery container with words “Universal Waste”, and a description such as “Spent Battery” or “Used Batteries”, as soon as the first battery is collected - or first goes into the container.
Date - Each battery or container must be marked with the date that the first battery was collected and/or put into the container.
Dispose - Each battery or container must be shipped off-site to an authorized Universal Waste handler within 12 months of the above date. To ensure compliance with this regulation, all Universal Waste batteries must be referred to IUPUI EHS for pick-up within 9 months.
General Rules Management of Universal Waste Fluorescent Bulbs
Fluorescent light bulbs come in different sizes and shapes; long, straight lamps used in ballast
operated light fixtures, or compact fluorescent bulbs used in place of incandescent bulbs. All
fluorescent bulbs or lamps contain a small amount of mercury. Bulbs known as “green” or
“green tip” contain mercury in low enough amounts to be exempt from waste regulations. They
can be distinguished from standard mercury bulbs by their green end-caps or other markings.
Collecting green lamps along with regular lamps for Universal Waste recycling is encouraged,
but not required.
All bulbs must be stored in a closed container to protect against breakage as soon as they are collected.
Use boxes that the bulbs came in or round fiber drums provided by the disposal vendor. Make sure to use a box or drum that is long enough to fully cover the entire length of the bulbs in the container.
Each container must be marked with the words “Universal Waste” and a description such as “Used Bulbs” or “Used Lamps” as soon as the first bulb goes into the container.
Each container must be marked with the date that the first bulb went into the container.
IUPUI Waste Management 57
Each container must be shipped offsite to an authorized Universal Waste handler before one year from the date marked on the container to avoid violation of the regulations.
If a bulb breaks before it is placed into a container, it is no longer a Universal Waste. The debris from the cleanup of the broken bulb must be managed as hazardous waste. Refer all broken lamps to EHS for disposal in a closed container with a waste chemical label that states “Broken Mercury Bulb Debris”.
Unknowns
Waste that is not labeled or accurately described in a way that allows IUPUI EHS to determine what
hazards it poses and how it should be disposed is deemed an “unknown” waste. Unknowns must be
analyzed by EHS to determine their basic chemical hazards through a time-consuming chemical
fingerprinting process. Due to the extra time, cost and resources associated with fingerprinting
unknowns, IUPUI EHS reserves the right to charge departments a cost-recovery fee per unknown
container. All fees will be discussed with the generator and their department before they are charged.
IUPUI disposes unknown wastes once fingerprinted via a hazardous waste vendor. The vendor puts
limitations on the size of unknowns. Thus, IUPUI EHS cannot receive unknown materials in containers
larger than 1 gallon, or solids larger than 1 kilogram. Larger amounts must be broken down into smaller
quantities by the generator.
IUPUI Waste Management 58
6.4 Cost Recovery
Under normal circumstances, IUPUI EHS does not charge for the cost of waste handling and
disposal services to academic or research groups. However, IUPUI EHS reserves the right to
charge the department of waste generators who incur regulatory fines as a result of non-
compliance with this Guide, or who require services that result in significant costs for IUPUI EHS
or to the University as a whole such as:
Disposable Cylinders: Many cylinders can be returned to the manufacturer for refill or recycling in quantities as low as 1lb. In most cases, disposable cylinders (non-returnable) with remaining pressure, product or product residue must be referred to IUPUI EHS for waste disposal. Empty cylinders can only be discarded as general refuse or scrap metal if they once contained an inert, non-toxic gas and are proven to be at atmospheric pressure by valve removal or puncture. IUPUI EHS reserves the right to charge back special handling or disposal charges incurred per disposable cylinder to the responsible department. Check with your department representative for returnable options before purchasing a disposable cylinder.
High-hazard Waste: Unstable, reactive or peroxide-forming chemicals that are improperly stored, mixed with incompatible materials or otherwise mishandled can pose serious risks, including fire or explosion. Due to the high-hazard nature of these materials, IUB EHS must contract special services for stabilization, transportation and disposal at an extremely high cost. IUB EHS reserves the right to charge back for specialized high-hazard waste management services per container.
Laboratory Chemical Moves: Personnel must comply with campus specific guidelines for inter and intra-building chemical moves IU Hazardous Materials Transportation Program. The program provide detailed procedures for notification of IUPUI EHS, timeframes, and preparation of materials. Preparation and move assistance from IUPUI EHS personnel is also available with adequate notification for a fee that includes time and materials. Responsible departments must ensure that guidelines are followed so that all chemicals, wastes, and contaminated items are identified and managed properly before a lab is vacated. IUPUI EHS charges the responsible department for any unreasonable costs incurred for the cleanout of labs that do not comply with the proper procedures.
Mercury: As part of the University’s waste minimization effort, and due to the high cost of disposal, all non-essential uses of mercury are prohibited at Indiana University. Authorization for essential uses of mercury and/or mercury compounds must be obtained from IUPUI EHS. Details are outlined in the Mercury Reduction/Elimination Policy. Charges related to disposal and/or spill cleanup of unauthorized mercury will be referred back to the generating department.
Unknown Fingerprinting: All chemical materials must be fully identified and labeled by the generator with adequate information for IUPUI EHS to determine potential hazards and a proper disposal method. Unidentified chemicals are expensive to dispose, and dangerous to emergency responders. IUPUI EHS reserves the right to charge the responsible department for each container of unknown material. The amount charged is determined by IUPUI EHS based on the cost of characterization and disposal.
The success of the IU Waste Management Program depends on the cooperation and conscientious efforts
of everyone at Indiana University. IUEHS provides guidance and helps manage the disposal of a wide
range of chemical waste from laboratories, shops, offices, etc. for off-site treatment or disposal. This
section outlines the general procedures for managing waste from laboratory and non-laboratory
operations on the regional campuses. Waste handling and disposal protocols for specific waste types
commonly generated by both of these operations, is also included. The procedures and methods provided
must be followed to ensure your health and safety as well as regulatory compliance. If you have any
questions, contact IUEHS for your respective campus.
7.1 Regional Campus Laboratory Waste Management The following general requirements apply to waste generated by laboratory operations.
Laboratories generate a large variety of waste types. Those waste types shall be managed as
hazardous waste unless otherwise specified by this Guide or IUEHS staff.
General Requirements
1. Identify and label – Note: All waste containers must be labeled! Containers are to be labeled at
the time the first waste is added, and subsequently add constituent names as needed.
Chemicals in original containers with intact labels do not need to be relabeled unless they are difficult to read. Small bottles may be labeled by any means which completely identifies the contents of the bottle, such as placing the small container(s) in a labeled, Ziploc® bag.
Pre-printed, Waste Chemical Labels are available from IUEHS (see Figure 7A). Labs can create, print and secure custom labels to the container; as long as all of the constituents contained in the waste and approximate concentration of each is provided. Avoid acronyms, chemical structures or abbreviations. Provide percentages of chemicals in a mixture, including water.
Waste Chemical Label information:
Waste Chemical Labels are available from IUEHS for your respective campus.
Waste Chemical Labels must state each chemical constituent present in the waste container and corresponding percentages. Waste constituents must be spelled out completely — no abbreviations, formulas or structures. Please write legibly.
Additional Waste Chemical Labels may be used, if necessary. Sign and date all Waste Chemical Labels used to identify the waste.
Affix Waste Chemical Label(s) to container(s) securely.
Fill in an accumulation date when the container is “full” and advise the Laboratory Safety Coordinator for your school/department. Note: “Full” is 90% of container capacity to allow for expansion.
2. Ensure waste containers are appropriate and in sound condition – Wastes managed by
IUEHS are transported within buildings and on University streets. Therefore, chemical waste must
be packaged in containers suitable for transportation. Acceptable waste containers for common
chemicals are as follows:
Flammable and halogenated solvents: Four-liter glass solvent bottles, one or five-gallon size metal cans or plastic carboys, or any original solvent container.
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Strong acids and bases: Glass or compatible plastic bottles up to 4 liters in volume, original bottles preferred.
Miscellaneous organic and inorganic reagents: Original containers or their equivalent.
Notes: Contact IUEHS for approval to use waste containers larger than 5 gallons in size. All containers should be approximately 90% full and must have tight sealing caps or lids (no Parafilm®). Wastes that are not packaged according to these specifications will not be managed by IUEHS until corrected.
3. Consolidate wastes wisely – Consolidating waste into fewer containers can seem efficient, and
can save space, resources, and even cost if done properly. However, it can lead to increased costs
and increased safety risks if the guidelines below are not followed:
Do not mix incompatible materials together in the same waste container. Attachment C provides more information on compatibility.
Oxidizers, strong acids (such as nitric and perchloric), and any water-reactive material, should never be consolidated with other waste at any concentration.
When possible, different wastes (solids vs. liquid, solvents vs. aqueous) should be accumulated in separate waste containers. This does not preclude mixing wastes that could obviously be mixed together, such as compatible solvent waste.
Do not mix high hazard rated materials with low hazard rated materials as wastes if the experimental procedure does not require it. Doing so may inadvertently create a large quantity of regulated hazardous waste where a much lower quantity may have existed otherwise.
If you don’t have a need to consolidate, are unsure whether or not your waste is compatible with the waste in your waste accumulation container, or your waste accumulation container is poorly labeled – don’t consolidate.
Note: Never assume the contents of unknown or poorly labeled containers, and never consolidate unknown or unidentified wastes with other waste materials.
4. Manage containers in accumulation areas properly - Good management of containers in
waste accumulation areas increases safety for everyone involved in handling and transporting
waste chemicals. All requirements in Attachment B in addition to the following guidelines must
be practiced to ensure safety and compliance.
Ensure waste containers are appropriate and in sound condition.
Keep containers closed at all times, unless actively adding waste.
Do not put corrosive waste in metal containers, as the containers will corrode and leak as well as evolve flammable hydrogen gas.
Accumulate non-solvent waste streams (acids, metals, etc.) separately from solvents. Solvents should be free of all other wastes, including aqueous wastes and water not mixed during the same procedure.
Separate incompatible materials. Acids must be kept separate from bases and cyanides, organic material separate from oxidizers, etc. Refer to Attachment C for more information on chemical compatibility.
Keep the outside of containers free of contamination.
Do not over-fill containers. Note: Full means 90% or less to allow for expansion within the container.
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Keep ignitable waste away from ignition sources.
Check product Safety Data Sheets (SDS) for information on ingredients and other hazard information to ensure proper storage.
Do not accumulate or store waste containers outdoors.
Label the container immediately upon adding chemicals to the container.
Full or ready to dispose of wastes shall be properly maintained in the department accumulation area. IUEHS staff will assist staff and help coordinate chemical waste disposal activities on a periodic basis. Should you have waste materials that are in immediate need of disposal, please contact IUEHS for your respective campus.
3. Manage the waste in the accumulation area so that the total quantity of chemical waste
(unless designated as non-hazardous by this Guide or IUEHS) remains under 55 gallons at all
times. Note: If you are approaching 55 gallons of waste in the accumulation area and a waste
pickup is not scheduled within 72 hours, notify IUEHS immediately.
5. Dispose – Once a waste accumulation container is full or a chemical has been determined to be
a waste chemical, it should be placed in the designated accumulation area and presented to
IUEHS for disposal as soon as reasonably possible. Advise the Laboratory Safety Coordinator for
your school/department when the accumulation container or waste chemical is placed in the
designated accumulation area (provide information on container type, its contents and the
quantity of material). Please keep in mind time limits provided for some waste types in Section
7.3 and Table 7A below. Storing waste past these time limits can result in regulatory citations
for the University.
Each regional campus maintains its own generator status with the Indiana Department of
Environmental Management. Table 7A summarizes restrictions/limitations/time limits for
various generator statuses. Contact IUEHS for more information about the generator status for
your respective campus and any restrictions/limitations/time limits that may apply. IUEHS
personnel will frequently check-in with Laboratory Safety Coordinators to facilitate compliance.
Dispose of waste in a timely manner. IUEHS offers ample opportunities for disposal. Safety and compliance is maximized when waste is disposed of on a regular basis.
At the time you present your waste to IUEHS for disposal, make sure that it is properly packaged and labeled. IUEHS will not accept waste that is not properly packaged, labeled, and dated.
Non-laboratory operations, such as facilities maintenance, information technology support, and
academic or administrative offices, often generate similar types of waste. This section outlines
the general requirements for managing non-lab waste materials. Additional guidance on handling
and disposal of specific waste types is found in the following section (Section 7.3).
General Requirements
1. Identify your waste. Section 7.3 lists common waste types at IU facilities. This information will guide you in identifying your waste and, for some wastes, in proper management of the waste. Unless the waste specific information indicates otherwise, steps 2-6 of this section must be followed for all wastes.
2. Label and date – Regulations require that all waste containers be labeled to identify the contents.
A label must identify the contents of the waste container. The description must be specific enough
that a person who does not work in the area could read it and know what the material is and what
hazards to expect. Containers must be labeled as soon as the waste is identified or, in the case of
an accumulation container like a bucket or a drum, as soon as the first waste is added. Additional
contents information must be added as additional waste is added. IUEHS requires that you use
the Waste Chemical Label. IUEHS will provide Hazardous Waste Labels, as needed.
Unless otherwise stated in this Guide, waste containers should not be dated until you are
ready to present them to IUEHS. You should manage the waste in your accumulation area so
that your total quantity of chemical waste (unless designated as non-hazardous by this Guide
or IUEHS) remains under 55 gallons at all times.
Note: If you are approaching 55 gallons of a specific waste in your accumulation area and a waste pickup is not scheduled within 72 hours, notify IUEHS immediately.
Some wastes, such as used oil, PCB ballasts, and Universal Waste have special labeling
requirements, and different accumulation time limits. See the next section (Section 7.3) under
each specific waste type for these special rules.
3. Consolidate wastes wisely – Consolidating waste into fewer containers can seem efficient and
can save space, resources, and even cost if done properly. However, it can lead to increased costs
and safety risks if the guidelines below are not followed.
Accumulate different waste types in separate containers (solids vs. liquids, solvents vs. oil, oil-based paint vs. latex paint). This simplifies tracking of waste constituents in each container for labeling purposes, reduces the risk of reaction between incompatible wastes, and avoids costly generation of excess regulated hazardous waste from potential mixing of non-hazardous wastes with hazardous wastes.
When possible, avoid re-using plastic containers for liquid waste other than containers provided by or approved by IUEHS. Plastic breaks down over time especially when exposed to adverse weather conditions.
Choose an accumulation container size that fits the quantity of waste that you will generate in a reasonable amount of time.
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4. Manage containers in accumulation areas properly – Good management of containers in
waste accumulation areas increases safety for everyone involved in handling and transporting
waste chemicals. All requirements in Attachment B in addition to the following are guidelines
that must be practiced to ensure safety and compliance.
Ensure waste containers are appropriate and in sound condition.
Keep containers closed at all times, unless actively adding waste.
Do not put corrosive waste in metal containers, as the containers will corrode and leak as well as evolve flammable hydrogen gas.
Accumulate non-solvent waste streams (acids, metals, etc.) separately from solvents. Solvents should be free of all other wastes, including aqueous wastes and water not mixed during the same procedure.
Separate incompatible materials. Acids must be kept separate from bases and cyanides, organic material separate from oxidizers, etc. Refer to Attachment C for more information on chemical compatibility.
Keep the outside of containers free of contamination.
Do not over-fill containers. Note: Full means 90% or less to allow for expansion within the container.
Keep ignitable waste away from ignition sources.
Check product Safety Data Sheets (SDS) for information on ingredients and other hazard information to ensure proper storage.
Do not accumulate or store waste containers outdoors.
Label the container immediately upon adding chemicals to the container.
Full or ready to dispose of wastes shall be properly maintained in the department accumulation area. IUEHS staff will assist staff and help coordinate chemical waste disposal activities on a periodic basis. Should you have waste materials that are in immediate need of disposal, please contact IUEHS for your respective campus.
5. Package – Containers must be packaged properly to be accepted IUEHS.
For containers <5 gallons:
Each container must have a properly completed, signed, and dated Waste Chemical Label attached securely.
The Waste Chemical Label must list all of the ingredients of the waste and their percentages. The percentages must add up to 100%. No acronyms or abbreviations are to be used on the Waste Chemical Label.
An SDS may be attached to the container along with the Waste Chemical Label if the waste is a chemical product and you do not know all of the ingredients.
Every effort must be made to ensure that waste containers are sound and that lids are tight sealing, even if that means the waste must be repackaged. If a problem with a container cannot be resolved, the container must be placed into an individual bucket with a lid, and the outside of the bucket must be labeled the same as the container would be.
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For containers >5 gallons (drum quantities):
Ensure bungs are tightened and there is no bulging from pressure build-up.
Each drum must have a properly completed Waste Chemical Label unless otherwise indicated in this Guide or by IUEHS.
If the waste pickup area cannot be accessed with a drum cart, or is only accessible by stairs, waste must be stored in 5 gallon containers or smaller so that they can be carried out.
6. Dispose – Once a waste accumulation container is full or a chemical has been determined to be
a waste chemical, it should be placed in the designated accumulation area and presented to
IUEHS for disposal as soon as reasonably possible. Advise IUEHS for your respective campus
when the accumulation container or waste chemical is placed in the designated accumulation
area (provide information on container type, its contents and the quantity of material). Please
keep in mind time limits provided for some waste types in Section 7.3 and Table 7A. Storing
waste past these time limits can result in regulatory citations for the University.
Each regional campus maintains its own generator status with the Indiana Department of
Environmental Management. Table 7A summarizes restrictions/limitations/time limits for
various generator statuses. Contact IUEHS for more information about the generator status
for your respective campus and any restrictions/limitations/time limits that may apply.
Dispose of waste in a timely manner. IUEHS offers ample opportunities for disposal. Safety and compliance is maximized when waste is disposed of on a regular basis.
At the time you present your waste to IUEHS for disposal, make sure that it is properly packaged and labeled. IUEHS will not accept waste that is not properly packaged, labeled, and dated.
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7.3 Regional Campus Management of Specific Waste Types
Acids or Bases (Laboratory operations only)
This section explains the disposal options for solutions of acids and bases from laboratories. It is best to
dispose of concentrated solutions of acids or bases with IUEHS due to the difficulty of neutralization. Use
only disposable containers for waste that will not be neutralized because these containers will not be
returned to you. Wastes that have been pre-approved by IUEHS for neutralization following the
neutralization procedures outlined in Section 4.1 are listed in Attachment A. If a material that you want
to neutralize is not listed in Attachment A, contact IUEHS for approval.
1. Concentrated acids
<25 ml and approved for sewer disposal in Attachment A - Follow neutralization procedures in Section 4.1 or dispose directly with IUEHS.
>25 ml or not approved for sewer disposal – Dispose directly with IUEHS.
2. Dilute acid solutions or concentrated or dilute base solutions with no toxic metals
Approved for sewer disposal in Attachment A - Follow neutralization procedures in Section 4.1 or dispose directly with IUEHS.
Not approved for sewer disposal – Dispose directly with IUEHS.
3. Dilute acid solutions or concentrated or dilute base solutions containing toxic metals
Dispose directly with IUEHS. Many toxic metals are regulated hazardous wastes at very low concentrations and IUEHS must make that determination.
Note: Nitric and perchloric acids are not approved for neutralization or consolidation at any concentration.
Aerosol Cans
Aerosol cans are pressurized and often contain flammable propellants. Even empty aerosol cans
remained slightly pressurized and should not be thrown away. Refer all aerosol cans to IUEHS for chemical
waste disposal. An exception to this would be non-flammable compressed air dusters, which can be
discarded as general refuse (however consult the SDS for the material to ensure the air duster does not
contain flammable propellants).
Air and Water Reactive Materials
Dispose of all air and water reactive materials, such as those listed below, through IUEHS. Package any
liquids separately from solids and note any special hazard and/or handling precautions on the Waste
Chemical Label.
Acetyl chloride Lithium metal Sodium metal
Bromine Phosphorus (yellow) Thionyl chloride
Calcium metal Potassium metal Trichlorosilane
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Animal Related Materials
Animal related materials such as waste food, water, bedding and animal carcasses must be handled
through the appropriate animal care facility unless the materials are contaminated with hazardous
chemicals. Animal-related materials that are contaminated with hazardous chemicals must be referred
to IUEHS for disposal. All chemical contaminants and potential biological hazards must be communicated
to IUEHS by the generator.
Asbestos Containing Materials
Asbestos containing materials (ACM’s) are commonly found in older University buildings. Examples can
include floor tiles, pipe insulation, plaster and caulk. The presence of asbestos in a building does not mean
that occupant health is at risk. As long as ACM’s remain in good condition, exposure is unlikely.
Do not remove or disturb asbestos containing materials. If asbestos or asbestos containing materials are
found, immediately report the nature and location of the material to IUEHS for evaluation. Whenever
possible, isolate the asbestos containing material by restricting access to the area in which it is found.
Aqueous Solutions of Toxic Metals
All aqueous solutions containing toxic metals must be disposed of by IUEHS. These toxic metals include:
Aluminum Chromium Nickel
Arsenic Copper Selenium
Barium Lead Silver
Cadmium Mercury* Zinc
Note: For any solutions containing mercury, the Waste Chemical Label must indicate whether the mercury
concentration is less than or greater than 260ppm.
Aqueous Solutions of Toxic Organic Chemicals
Keep organic wastes separate from aqueous waste so that unnecessary aqueous organic waste streams
are not generated. It is more difficult and more expensive for IUEHS to dispose of combination
aqueous/organic wastes.
Ballasts
Ballasts are used in fluorescent bulb light fixtures. Ballasts from lighting maintenance activities may
contain polychlorinated biphenyls (PCB). The other two types are non-PCB and electronic ballasts.
PCB ballasts contain a toxic liquid and are regulated by EPA’s Toxic Substance Control Act (TSCA).
Only ballasts manufactured before 1979 contain PCB. All ballasts should be inspected for a
marking that states in some way that the ballast does not contain PCB. If no such wording is
located, the ballast(s) must be referred to IUEHS for disposal. Non-PCB ballasts can be discarded
as trash or scrap metal. See also: Polychlorinated Biphenyls
Non-PCB ballasts can be discarded as general refuse or salvaged for scrap metal if an outlet is
available. IUEHS does not manage or dispose of these.
Electronic ballasts contain a Ni-Cad battery that must be removed. Refer the battery to
Facilities/Physical Plant for disposal. Discard the ballast as general refuse or salvage metal scrap.
IUEHS does not manage or dispose of these.
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Batteries
Most batteries are regulated by the Environmental Protection Agency as Universal Waste, which are
special regulations for hazardous waste batteries designated for recycling. However, University
operations that sporadically generate spent batteries from laptops, cell phones, or other electronic
devices should segregate batteries by type. Most batteries are marked with a symbol or abbreviation that
indicates battery type. Manage batteries in the following manner:
Alkaline – Unfortunately there is limited net value to recycling alkaline batteries. These are not regulated, and can be discarded in the general refuse (trash). Some regional campus facilities have collection containers where these can be deposited for disposal separate from general refuse (trash).
For the following battery types, tape the terminals and dispose through IUEHS or Facility Services/Physical Plant (FS/PP), as appropriate, for your respective campus.
Lead-acid
Lithium
Nickel-cadmium
Nickel-metal hydride
Mercury
If collecting batteries for recycling in a container over a period of time, follow Universal Waste rules for
labeling and accumulation time limits.
Biological Materials
Biological materials, including unfixed human or animal tissue, must be treated according to approved
protocols (either autoclave or chemical disinfectant) before disposal. Autoclave indicator tape must be
used and the universal biohazard symbol must be defaced to confirm that the waste has been treated.
Biological materials and fixed tissues that are chemically treated or otherwise mixed with chemicals must
be referred to IUEHS for waste disposal. More information can be found in the IU Biosafety Manual.
Cardboard
Cardboard recycling at the regional campuses is part of the larger recycling effort coordinated by FS/PP
and/or sustainability committees.
Cardboard that is grossly contaminated with chemical(s) that exhibit flammable, corrosive, reactive
and/or toxic characteristics must be placed in a sealed container and disposed through IUEHS following
the general procedures in Section 7.1 or 7.2, as appropriate.
Chemical Waste
Since IUEHS determines which chemicals are regulated as hazardous waste, all unwanted chemicals must
be managed as hazardous waste when discarded unless specific instructions in this Guide or IUEHS
personnel state otherwise (see Annex 1). Departments that generate hazardous chemical waste must
follow Satellite Accumulation Area Requirements (Attachment B). All IUEHS general requirements for
waste management must also be followed. Discard chemical waste often to avoid deterioration of
Follow all general requirements in Section 7.1 for any chemicals or chemical wastes to be discarded,
and check this section (Section 7.3) for any additional requirements for specific waste types.
Non-Laboratory Operations
Non-laboratory chemical waste may be generated by maintenance, custodial, landscaping, or other
facilities operations. Common examples include:
Aerosols and cylinders such as propane tanks;
Cleaning compounds (many are corrosive);
Pesticides with toxic ingredients;
Mercury and mercury debris;
Paints (oil based), solvents, stains and adhesives;
Pool or water treatment chemicals;
Fuels and fuel/oil mixtures; and
Spill debris from hazardous chemical spills. Follow all general requirements in Section 7.2 for any of the above materials or any other chemical product to be discarded, and check this section (Section 7.3) for any additional requirements for specific waste types.
Chemically Contaminated Items (CCIs)
Chemically contaminated items (CCIs) such as disposable lab ware, gloves, bench top coverings, pipets,
test tubes, aprons, etc. can be put into the normal trash if they are not reactive, ignitable, infectious, or
radioactive; the contaminant is not highly toxic; and the material will not cause a nuisance or physical
hazard when placed in the trash. If your CCI contaminant is not listed in Attachment A and you are unsure
whether normal trash is an appropriate disposal route for your CCIs, contact IUEHS for approval prior to
disposal.
If your CCIs cannot be placed in the normal trash for one of the above reasons, package them in a 5-gallon
plastic bag which can be placed conveniently inside a 5-gallon plastic bucket. The bag should be at least
2ml thick. Close the bag with a rubber band, twist tie, or by tying the top when it is full, and label the
Waste Chemical Label as "chemically contaminated items" or "CCIs" and list all chemical contaminants.
Call IUEHS if you have any questions.
Note: All PCB contaminated materials at 50 ppm must be packaged separately, and referred to IUEHS for
disposal with the PCB concentration clearly indicated on the Waste Chemical Label.
Compressed Gases
Compressed gas cylinders that are no longer wanted should be disposed in a timely manner to prevent
deterioration. Leased cylinders should be closed, capped and returned to the original gas supplier. Non-
returnable cylinders such as lecture bottles and disposable cylinders should be referred to IUEHS for
disposal. Indicate on the cylinder whether it is at atmospheric pressure, or if it is above 1 atmosphere of
pressure.
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Controlled Substances
Controlled substances are regulated by the US Drug Enforcement Agency (DEA) on Schedules I-V. These
materials require registration with the DEA, careful inventory protocols, and documentation of on-site
destruction. If for any reason controlled substances cannot be witness-destroyed on site by the original
registrant, arrangements need to be made in advance with IUEHS. IUEHS will coordinate with the
registrant or registrant’s departmental representative (in case of abandoned materials or deceased
registrant), IU Police and the local DEA office for controlled substances on-site destruction or disposal.
See the IU Controlled Substances Program for Research (Non-Practitioners).
2, 4-Dinitrophenol
This chemical (2, 4-DNP or α-Dinitrophenol) poses an explosive hazard when it becomes dry. It must be
wetted to at least 15% water for shipment. Thus, this chemical must never be stored in a desiccator or
under any other conditions that would allow for the material to dry out such as storing it for an extended
period of time. Unwanted 2, 4-DNP must be disposed of in a timely manner. Do not touch 2, 4-
dinitrophenol that appears old or dried out. You must contact IUEHS, and we will come evaluate the
material. See also: Explosive or Shock-Sensitive Compounds.
Electronic Equipment
Electronic waste (E-waste) contains toxic metals in components like screens and circuitry, but is exempt
from hazardous waste regulations as long as the equipment is intact. If equipment is crushed and leaking,
contact IUEHS for guidance. Most e-waste is currently managed at the regional campuses by Indiana
University Information Technology Services (UITS). Examples of common e-waste at regional campuses
include:
Computer monitors,
Printers,
Mobile phones,
Video equipment,
Speakers, and
Laptops.
Empty Containers
Bottles and containers are considered “empty” when you have removed all contents possible by normal
means (pouring, scooping, etc.). There may still be some residue clinging to the inside walls of the
container, but these may be placed in the normal trash. Punch a hole in 5-gallon metal containers or safety
cans that are no longer needed, and place directly in the normal trash dumpster. This will prevent their
Notes: If you intend to dispose of more than one liter of a non-hazardous liquid or 5 pounds of solid, or if the material is not listed in Attachment A of this Guide, contact IUEHS prior to disposal for approval.
Non-Laboratory Operations
Some materials are not hazardous, but still cannot be disposed directly into the trash because of
landfill restrictions. The most common restriction encountered is that liquids and semi-liquids are not
allowed to be landfilled. Many oils, latex paint, and other water-based materials are non-hazardous
and could be landfilled if they were solid, but cannot be when they are liquid.
Spill debris from non-hazardous wastes can be discarded in the trash, as long as all free liquid is
absorbed. Minimal amounts of liquid in otherwise empty containers of non-hazardous wastes can be
absorbed with kitty litter or other suitable absorbent material and disposed in the trash also.
Common examples of non-hazardous chemical waste include:
Antifreeze and other glycols;
Latex paint;
Non-toxic pesticides (such as dormant oil), fertilizers and plant food;
Oils (non-PCB) and cutting fluid; and
Water-based coatings, detergents and surfactants.
Oil
Various types of oil, including vacuum pump oil, motor oil, cutting oils, etc., that is not contaminated with
solvent or other chemicals, must be referred to IUEHS or FS/PP, as appropriate for your respective campus
for recycling. Any used oil that is contaminated with other chemicals must be accurately described and
disposed as a chemical waste through IUEHS. If the oil contains PCB, the generator must indicate such on
the label and as part of the chemical description on the Waste Chemical Label. The concentration of PCB
in parts per million (PPM) should also be listed if known. See also: Polychlorinated Byphenyls and Vacuum
Pump Oil.
Paint and Paint Products
Latex paint that is still in good condition, even if the container has been opened, should be redistributed
if no longer wanted/needed. If a new recipient department is not found, latex paint can be solidified and
disposed of in the general refuse (trash). Paint that contains lead, is oil based, or in an aerosol can (spray
paint), must be referred to IUEHS for waste chemical disposal. Lead-based paint chips from construction
or remediation must also be referred to IUEHS for disposal. See also: Lead.
Peroxide Formers
A variety of chemicals can form highly explosive peroxide compounds when exposed to air. Peroxides are
sensitive to heat, friction, impact, and light and are among the most hazardous chemicals encountered in
the laboratory. Care must be taken to prevent the formation of peroxides in these chemicals.
Preventing the formation of peroxides is dependent on inventory control of peroxide-forming chemicals.
Most of these materials are distributed with inhibitors to drastically slow peroxide formation. These are
usually effective until the container is first opened. To prevent peroxide hazards, peroxiding-forming
chemicals must be dated both upon receipt and upon opening. These materials must also be discarded as
waste through IUEHS within the timeframes listed below.
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IUEHS requirements for peroxide former waste acceptance are:
The material must be less than twelve months old. This information must be marked clearly
on the Waste Chemical Label.
If the material is greater than twelve months old but less than two years old, check for
peroxide formation by using peroxide test strips. If peroxide formation is detected, mark the
test result in parts per million (PPM) on the Waste Chemical Label, along with the date tested.
Request a waste pick-up immediately. If peroxide formation is greater than 100 ppm,
immediately call IUEHS for technical assistance.
If the material is greater than 2 years old but less than 5 years old, it should be assessed for
other factors such as: duration of exposure to sunlight; volume of container; security of the
seal; and exposure to changes in temperature. If you do not know the answer to any of these
questions, find someone who does. Do not open the container to check for peroxide
formation, as the material could be shock-sensitive. Call IUEHS immediately for technical
assistance.
If the container is more than five years old, do not move the container. Post a sign reading
"DANGER: possible shock-sensitive chemical" and immediately call IUEHS for technical
assistance.
Safety Tips for Peroxide Formers
Date peroxide formers when received and when first opened. In general, discard according to time limitations suggested by the manufacturer. For severe and high peroxide formation hazard chemicals, the storage limitations are:
must be collected and accumulated according to the following guidelines:
They must be accumulated in your area in non-leaking containers that are closed at all times except when wipes and rags are being added.
The accumulation containers must be labeled with the words “excluded solvent-contaminated wipes” or with other words that accurately describe the container contents.
The containers must be shipped off-site for disposal within 180 days of the date that the first wipe or rag was placed in the drum. To ensure that this time limit is being heeded, IUEHS requires the containers to be dated when the first material is added, and for the containers to be transferred to IUEHS or to a reusable wipe/rag laundry service within 5 months.
Wipes and rags must not contain free liquids when they are offered for disposal.
If you use a laundry service for reusable wipes or rags, you must maintain the following information and make it available to IUEHS for inspection:
o Name and address of the laundry service.
o Shipment records showing that the 180-day accumulation time limit is being met.
o A description of the process that you use to make sure that the wipes or rags contain no free liquids when shipped off-site.
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Spill Debris
For liquid spills that meet all of the reporting exception criteria listed in Section 8 of this Guide, absorb
with spill pads or disposable towels and place them into a sealed container or leak resistant bag. After
absorption, use a small amount of soap and water to clean spill surfaces and dry thoroughly. For solids,
sweep up the spill with a broom and dustpan. Collect the material into a plastic or glass container or
Ziploc® bag. Do not use a shop vac or vacuum cleaner.
For inert, non-hazardous chemical spills, place in a sealed container, including the broken chemical
container, contaminated towels, etc. for general trash disposal. Be sure all liquid spills are fully absorbed
into paper or cloth towels or spill pads.
For spills involving material that must be managed by IUEHS, the debris must be in a closed container
labeled as “Spill debris containing…” and a detailed list of the contents. Include everything in the
container such as broken glass or metal if present, water, paper towels, etc.
Strong Oxidizers and Reducers
Refer all strong oxidizers and reducers to IUEHS for disposal. Keep these items separate from each other,
Some chemicals must be stored at constant, low temperatures to maintain their stability or integrity.
These can include organic peroxides, self-reactive solids, and highly volatile compounds that must be kept
cold in order to prevent thermal decomposition, fire and explosion, or container pressurization. For
temperature controlled substance waste disposal:
Keep the material in appropriate cold storage according to the manufacturer.
Note the required temperature range needed to maintain stability of the waste and the specific location of the waste when contacting IUEHS for disposal.
You must store potentially flammable materials in specialized refrigerator/freezers. These materials are prohibited from storage in regular, household-type refrigerator/freezer units.
Universal Waste
Some waste materials meet the definition of a hazardous waste, but the EPA provides an exemption for
certain materials destined for recycling. However, generators of Universal Waste must still comply with
rules for accumulation, including segregation of waste types, labeling, and time limits. IU manages
fluorescent lamps and batteries as Universal Waste. See Attachment D for printable labels. Note: Spill
debris from Universal Waste must be managed as a hazardous chemical waste. See also: Batteries and
Fluorescent Light Bulbs.
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General Rules for Management of Universal Waste Batteries
These rules apply to maintenance areas where batteries may be stored before proper
recycling/disposal. The general requirements for Universal Waste Batteries are:
Inspect batteries for condition issues such as corrosion, cracks or leaking. Regulations require that leaking batteries must be placed in a closed container with tight-fitting lid. Batteries with no condition issues can be placed in an open container.
Note: Large lead-acid batteries found in vehicles and forklifts are not completely sealed at
the top (they are “spillable”); thus they must be stored upright. Do not store spillable
batteries outdoors or near floor drains. These batteries contain sulfuric acid. If a lead-
acid battery tips over and spills, follow campus emergency procedures for chemical spills.
Label each battery or battery container with words “Universal Waste”, and a description such as “Spent Battery” or “Used Batteries”, as soon as the first battery is collected - or first goes into the container.
Date - Each battery or container must be marked with the date that the first battery was collected and/or put into the container.
Dispose - Each battery or container must be shipped off-site to an authorized Universal Waste handler within 12 months of the above date. To ensure compliance with this regulation, all Universal Waste batteries must be referred to FS/PP or IUEHS as appropriate for your respective campus.
General Rules for Management of Universal Waste Fluorescent Bulbs
Fluorescent light bulbs come in different sizes and shapes; long, straight lamps used in ballast
operated light fixtures, or compact fluorescent bulbs used in place of incandescent bulbs. All
fluorescent bulbs or lamps contain a small amount of mercury. Bulbs known as “green” or “green
tip” contain mercury in low enough amounts to be exempt from waste regulations. They can be
distinguished from standard mercury bulbs by their green end-caps or other markings. Collecting
green lamps along with regular lamps for Universal Waste recycling is encouraged, but not
required.
All bulbs must be stored in a closed container to protect against breakage as soon as they are collected.
Use boxes that the bulbs came in or round fiber drums provided by the disposal vendor. Make sure to use a box or drum that is long enough to fully cover the entire length of the bulbs in the container.
Each container must be marked with the words “Universal Waste” and a description such as “Used Bulbs” or “Used Lamps” as soon as the first bulb goes into the container.
Each container must be marked with the date that the first bulb went into the container.
Each container must be shipped offsite to an authorized Universal Waste handler within 12 months of the above date to avoid violation of the regulations.
If a bulb breaks before it is placed into a container, it is no longer a Universal Waste. The debris from the cleanup of the broken bulb must be managed as hazardous waste. Refer all broken lamps to IUEHS for disposal in a closed container with a Waste Chemical Label that states “Broken Mercury Bulb Debris”.
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Unknowns
Unlabeled or poorly labeled containers of chemicals or products in areas where hazardous materials are
used or stored represent serious legal and safety problems for the University. They must be assumed
hazardous unless evidence or certification to the contrary can be obtained.
Without an accurate description, it is difficult to characterize the hazards presented and dispose of the
material legally and safely. Disposal companies will not accept chemical waste without an analysis or
specifically defined characterization of hazards.
It is the responsibility of the person generating a waste to accurately keep track of the contents of
containers so that the material can be described adequately for the disposal vendor when it is discarded.
If proper labeling and records on containers are not maintained and an adequate description cannot be
provided; or if the disposal company requires further analysis, it will result in a more costly disposal for
the University, and ultimately to you as the generating campus/department/individual.
Vacuum Pump Oil
Uncontaminated vacuum pump oil should be referred to FS/PP or IUEHS as appropriate for your respective
campus. Contaminated vacuum pump oil should be marked or labeled as a waste chemical with the words
“Used Pump Oil” and, if known, “contaminated with (list all known chemical contaminants)”.
Contaminated pump oil must be referred to IUEHS for disposal as a waste chemical. See also: Oil.
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Section 8: Spill Response Procedures
It is essential that all personnel who work around chemicals know how to response in the event of an
accidental chemical spill. IUEHS has developed the Biological, Chemical, Radiological Spill Reporting
and Response Program to provide guidance in these situations.
In accordance with the Biological, Chemical, Radiological Spill Reporting and Response Program, all
chemical spills must be reported to IUEHS. Do not attempt to clean up spills involving chemicals that are
flammable, toxic, corrosive or reactive as indicated on the label or SDS; or that cause eye or respiratory
tract irritation; or chemicals that emit strong, or noxious odors or fumes.
The following spills are exempted from the reporting requirements provided that ALL of the following conditions are met:
1. Personnel directly involved in the spill have immediate access to the Hazardous Materials Information System (HMIS) rating for the chemical and the chemical has a rating of 0 or 1 for health, fire and reactivity and Globally Harmonized System (GHS) health, fire and reactivity ratings of 5 or 4.
2. The amount spilled is less than one (1) pint (~500 milliliters), if liquid, or one (1) pound (~500 grams), if solid, unless it is lubricating oil or latex paint, then the amount spilled may not exceed 1 gallon (~4 liters).
3. The material does not possess a noxious, nauseating or otherwise irritating odor or property.
4. The released material is contained on an impervious surface and has not and is not immediately threatening to contaminate soil, groundwater or surface water.
It is the responsibility of the spiller to ensure that spills involving small quantities of chemicals are cleaned up immediately, stored and disposed of properly. Regularly occurring leaks or spills are not exempted from the reporting requirements.
A spill kit capable of cleaning up exempted quantities of spilled material is to be kept on-site. In some circumstances, IUEHS may authorize trained onsite personnel to clean up a spill that does not meet the exceptions above.
Procedures for spills of biological and radioactive materials are addressed in the IU Biosafety Manual and the Radiation Safety Manual respectively.